SUMMITAS INVESTMENT MANAGEMENT LLC

Summitas Investment Management LLC Form ADV Part 2A – Disclosure Brochure Effective: July 1, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Summitas Investment Management LLC (“Summitas” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 254-275-5326 or by email at imsummitas@outlook.com. Summitas is a registered investment advisor with the U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Summitas to assist you in determining whether to retain the Advisor. Additional information about Summitas and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 330721. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Summitas. For convenience, the Advisor has combined these documents into a single disclosure document. Summitas believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Summitas encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 21, 2025: • The Advisor no longer maintains an institutional relaitonship with Raymond James & Associates, Inc. Please see Items 12 and 14 for additonal information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 330721. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 254-275-5326 or by email at imsummitas@outlook.com. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 5 D. Wrap Fee Programs ........................................................................................................................................................ 5 E. Assets Under Management ............................................................................................................................................. 5 Item 5 – Fees and Compensation ......................................................................................................................... 5 A. Fees for Advisory Services.............................................................................................................................................. 5 B. Fee Billing........................................................................................................................................................................ 6 C. Other Fees and Expenses .............................................................................................................................................. 6 D. Advance Payment of Fees and Termination ................................................................................................................... 6 E. Compensation for Sales of Securities ............................................................................................................................. 7 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 7 Item 7 – Types of Clients ....................................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 7 A. Methods of Analysis ........................................................................................................................................................ 7 B. Risk of Loss ..................................................................................................................................................................... 7 Item 9 – Disciplinary Information .......................................................................................................................... 8 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 8 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 9 A. Code of Ethics ................................................................................................................................................................. 9 B. Personal Trading with Material Interest ........................................................................................................................... 9 C. Personal Trading in Same Securities as Clients ............................................................................................................. 9 D. Personal Trading at Same Time as Client ...................................................................................................................... 9 Item 12 – Brokerage Practices .............................................................................................................................. 9 A. Recommendation of Custodian[s] ................................................................................................................................... 9 B. Aggregating and Allocating Trades ............................................................................................................................... 10 Item 13 – Review of Accounts ............................................................................................................................. 10 A. Frequency of Reviews ................................................................................................................................................... 10 B. Causes for Reviews ...................................................................................................................................................... 10 C. Review Reports ............................................................................................................................................................. 10 Item 14 – Client Referrals and Other Compensation ........................................................................................ 11 A. Compensation Received by Summitas ......................................................................................................................... 11 B. Compensation for Client Referrals ................................................................................................................................ 11 Item 15 – Custody ................................................................................................................................................. 11 Item 16 – Investment Discretion ......................................................................................................................... 11 Item 17 – Voting Client Securities ....................................................................................................................... 12 Item 18 – Financial Information ........................................................................................................................... 12 Form ADV Part 2B – Brochure Supplement ....................................................................................................... 13 Privacy Policy ....................................................................................................................................................... 16 Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 3  Item 4 – Advisory Services A. Firm Information Summitas Investment Management LLC (“Summitas” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Texas. Summitas was founded in September 2023 and is owned and operated by John Shao (President, Owner and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Summitas. B. Advisory Services Offered Summitas offers investment advisory services to individuals and high net worth individuals (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Summitas's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Summitas provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Summitas works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Summitas will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks or bonds to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Summitas’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Summitas will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Summitas evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Summitas may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Summitas may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Summitas may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Summitas accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 4  IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging Summitas to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Summitas, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Summitas will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Summitas will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Summitas will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Summitas does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Summitas. E. Assets Under Management As of December 31, 2024,Summitas manages approximately $131,000,000 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly in advance, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedules: Annual Rate (%) US Based Clients Assets Under Management ($) Up to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $6,000,000 $6,000,001 and over 1.50% 1.25% 1.00% 0.75% Annual Rate (%) Non-US Based Clients Assets Under Management ($) Up to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $6,000,000 $6,000,001 and over 1.80% 1.50% 1.20% 0.90% Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 5  The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Summitas will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Summitas at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Summitas to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Summitas, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Summitas are separate and distinct from these custody and execution fees. In addition, all fees paid to Summitas for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Summitas, but would not receive the services provided by Summitas which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Summitas to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Summitas may be compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 6  E. Compensation for Sales of Securities Summitas does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Summitas does not charge performance-based fees for its investment advisory services. The fees charged by Summitas are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Summitas does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Summitas offers investment advisory services to individuals and high net worth individuals. Summitas generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Summitas primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from Summitas are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Summitas generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Summitas will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Summitas may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Summitas will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 7  Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Summitas or its owner. Summitas values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 330721. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Summitas and John Shao is to provide investment advisory services to its Clients. Neither Summitas nor its Advisory Persons are involved in other business endeavors. Summitas does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 8  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Summitas has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Summitas (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Summitas and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Summitas’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 254-275-5326 or via email at imsummitas@outlook.com. B. Personal Trading with Material Interest Summitas allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Summitas does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Summitas does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Summitas allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Summitas conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Summitas allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Summitas, or any Supervised Person of Summitas, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Summitas does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Summitas to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Summitas does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by- trade basis. Where Summitas does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Summitas. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Summitas may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 9  The Advisor will generally recommend that Clients establish their account[s] at Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”). Fidelity is a FINRA-registered broker-dealer and New York Stock Exchange/SIPC member and will serve as the Client’s “qualified custodian”. The Advisor maintains institutional relationships with Fidelity, whereby the Advisor receives economic benefits from the Custodian. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Summitas does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Summitas does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Summitas will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Summitas will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Summitas will execute its transactions through the Custodian as authorized by the Client. Summitas may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by John Shao, Chief Compliance Officer of Summitas. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Summitas if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 10  all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Summitas Summitas is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Summitas does not receive commissions or other compensation from product sponsors, broker-dealers or any un- related third party. Summitas may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Summitas may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform (Fidelity) As noted in Item 12, the Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from Fidelity: reimbursement to Clients for transfer costs to the platform/custodian; financing services, receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Summitas does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Summitas exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Summitas to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Summitas to ensure accuracy, as the Custodian does not perform this review. Item 16 – Investment Discretion Summitas generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Summitas. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Summitas will be in accordance with each Client's investment objectives and goals. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 11  Item 17 – Voting Client Securities Summitas does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Summitas, nor its management, have any adverse financial situations that would reasonably impair the ability of Summitas to meet all obligations to its Clients. Neither Summitas, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Summitas is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 12  Form ADV Part 2B – Brochure Supplement for John Shao, Ph.D., CFA® President, Owner and Chief Compliance Officer Effective: July 1, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John Shao, Ph.D., CFA® (CRD# 3020236) in addition to the information contained in the Summitas Investment Management LLC (“Summitas” or the “Advisor”, CRD# 330721) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Summitas Disclosure Brochure or this Brochure Supplement, please contact us at 254-275-5326 or by email at imsummitas@outlook.com. Additional information about Dr. Shao is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3020236. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 13  Item 2 – Educational Background and Business Experience John Shao, Ph.D., CFA®, born in 1963, is dedicated to advising Clients of Summitas as the President, Owner and Chief Compliance Officer. Dr. Shao earned a Ph.D. in Finance from Virginia Polytechnic Institute and State University in 1991. Dr. Shao also earned a Master of Science in Statistics from Virginia Polytechnic Institute and State University in 1989. Dr. Shao also earned a Master of Arts in Business from University of Texas at Dallas in 1987. Dr. Shao also earned a Bachelor of Electrical Engineering from Tsinghua University in 1984. Additional information regarding Dr. Shao’s employment history is included below. Employment History: 04/2024 to Present 07/2020 to 04/2024 02/1998 to 12/2020 President, Owner and Chief Compliance Officer, Summitas Investment Management LLC Investment Advisor Representative, Eudaimonia Partners, LLC Owner, President, Chief Compliance Officer, John Shao Portfolio Management, Inc. Associate Professor of Finance, Oklahoma City University 09/1991 to 08/2004 Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Dr. Shao. Dr. Shao has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Dr. Shao. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Dr. Shao. However, we do encourage you to independently view the background of Dr. Shao on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with [his/her] full name or [his/her] Individual CRD# 3020236. Item 4 – Other Business Activities Dr. Shao is dedicated to the investment advisory activities of Summitas’s Clients. Dr. Shao does not have any other business activities. Item 5 – Additional Compensation Dr. Shao is dedicated to the investment advisory activities of Summitas’s Clients. Dr. Shao does not receive any additional forms of compensation. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 14  Item 6 – Supervision Dr. Shao serves as the President, Owner and Chief Compliance Officer of Summitas. Dr. Shao can be reached at 254-275-5326. Summitas has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Summitas. Further, Summitas is subject to regulatory oversight by various agencies. These agencies require registration by Summitas and its Supervised Persons. As a registered entity, Summitas is subject to examinations by regulators, which may be announced or unannounced. Summitas is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 15  Privacy Policy Effective: July 1, 2025 Our Commitment to You Summitas Investment Management LLC (“Summitas” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Summitas (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Summitas does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 16  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Summitas does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Summitas or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Summitas does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 254-275-5326 or via email at imsummitas@outlook.com. Summitas Investment Management LLC 5704 Squeezepenny Lane, McKinney, TX 75070 Phone: 254-275-5326 Page 17