Overview

Assets Under Management: $225 million
Headquarters: MATTHEWS, NC
High-Net-Worth Clients: 65
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting

Fee Structure

Primary Fee Schedule (FORM ADV 2A AND 2B)

MinMaxMarginal Fee Rate
$0 $500,000 1.10%
$500,001 $1,000,000 0.90%
$1,000,001 $3,000,000 0.70%
$3,000,001 and above Negotiable
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million Negotiable Negotiable
$10 million Negotiable Negotiable
$50 million Negotiable Negotiable
$100 million Negotiable Negotiable

Clients

Number of High-Net-Worth Clients: 65
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 58.34
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 804
Discretionary Accounts: 804

Regulatory Filings

CRD Number: 121112
Last Filing Date: 2025-01-15 00:00:00
Website: https://tasselcapital.com

Form ADV Documents

Primary Brochure: FORM ADV 2A AND 2B (2025-07-22)

View Document Text
Tassel Capital Management Form ADV Part 2A – Disclosure Brochure Effective: July 14, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Tassel Capital Management (“Tassel Capital” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (704) 814-6780. Tassel Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Tassel Capital to assist you in determining whether to retain the Advisor. Additional information about Tassel Capital and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 121112. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the “Disclosure Brochure”) and Part 2B (the “Brochure Supplement”). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Tassel Capital. For convenience, the Advisor has combined these documents into a single disclosure document. Tassel Capital believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Tassel Capital encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on January 31, 2024. 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# 121112. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (704) 814-6780. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 2 Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................. 1 Item 2 – Material Changes....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 Item 4 – Advisory Services ..................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 5 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ........................................................................................................................... 6 A. Fees for Advisory Services.............................................................................................................................................. 6 B. Fee Billing........................................................................................................................................................................ 7 C. Other Fees and Expenses .............................................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................................... 7 E. Compensation for Sales of Securities ............................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 8 Item 7 – Types of Clients......................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8 A. Methods of Analysis ........................................................................................................................................................ 8 B. Risk of Loss ..................................................................................................................................................................... 9 Item 9 – Disciplinary Information ......................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10 A. Code of Ethics ............................................................................................................................................................... 10 B. Personal Trading with Material Interest ......................................................................................................................... 11 C. Personal Trading in Same Securities as Clients ........................................................................................................... 11 D. Personal Trading at Same Time as Client .................................................................................................................... 11 Item 12 – Brokerage Practices ............................................................................................................................. 11 A. Recommendation of Custodian[s] ................................................................................................................................. 11 B. Aggregating and Allocating Trades ............................................................................................................................... 12 Item 13 – Review of Accounts .............................................................................................................................. 12 A. Frequency of Reviews ................................................................................................................................................... 12 B. Causes for Reviews ...................................................................................................................................................... 12 C. Review Reports ............................................................................................................................................................. 12 Item 14 – Client Referrals and Other Compensation ......................................................................................... 12 A. Compensation Received by Tassel Capital................................................................................................................... 12 B. Client Referrals from Promoters .................................................................................................................................... 13 Item 15 – Custody .................................................................................................................................................. 13 Item 16 – Investment Discretion ........................................................................................................................... 13 Item 17 – Voting Client Securities ........................................................................................................................ 14 Item 18 – Financial Information ............................................................................................................................ 14 Form ADV Part 2B – Brochure Supplement(s) ................................................................................................... 15 Privacy Policy......................................................................................................................................................... 25 Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 3 Item 4 – Advisory Services A. Firm Information Tassel Capital Management (“Tassel Capital” or the “Advisor”) is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Corporation under the laws of the State of North Carolina. Tassel Capital was founded in May 2002 and is owned and operated by William Ertel (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Tassel Capital. B. Advisory Services Offered Tassel Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, and retirement plans (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. Tassel Capital’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Tassel Capital provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Tassel Capital 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. Tassel Capital will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts 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. Tassel Capital’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Tassel Capital will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Tassel Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Tassel Capital may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Tassel Capital may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Tassel Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client rollover its retirement plan account into an account managed by the Advisor. In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). 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 rollover. No client is under any obligation to roll over retirement plan assets to an account managed by the Advisor. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 4 At no time will Tassel Capital accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services Tassel Capital will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Tassel Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Tassel Capital provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services available include: Investment Management (ERISA 3(38)) • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • Performance Reporting • Ongoing Investment Recommendation and Assistance • Provider Search These services are provided by Tassel Capital serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Tassel Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Tassel Capital to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 5 • Establishing an Investment Strategy – Tassel Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Tassel Capital will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Tassel Capital will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Tassel Capital will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Tassel Capital does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Tassel Capital. E. Assets Under Management As of December 31, 2024, Tassel Capital manages $225,371,140 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, advance of each quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule: Annual Rate (%) Assets Under Management ($) Up to $500,000 $500,001 to $1,000,000 $1,000,001 to $3,000,000 Over $3,000,000 1.10% 0.90% 0.70% Negotiable 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 Tassel Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Financial Planning Services Tassel Capital offers financial planning services either on an hourly basis or for a fixed project-based fee. Hourly fees range up to $250 per hour. Fixed project-based fees for financial planning are based on the expected number of hours to complete the engagement at the aforementioned hourly rate. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 6 Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00% based on the market value of assets under management in the Plan. Retirement plan advisory fees are billed quarterly either in advance or in arrears of each quarter. Fees may be negotiable depending on the size and complexity of the Plan. 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 or the fees may also be invoiced directly to the Client. 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 Tassel Capital at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review 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 Tassel Capital to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Tassel Capital, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian may charge for mutual funds and other types of investments. The fees charged by Tassel Capital are separate and distinct from these custody and execution fees. In addition, all fees paid to Tassel Capital for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Tassel Capital, but would not receive the services provided by Tassel Capital which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Tassel Capital to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Tassel Capital 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 Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 7 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. Financial Planning Services Tassel Capital requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to the end of the quarter. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Tassel Capital may be compensated in advance or in arrears of the quarter in which retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan 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. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non- transferable without the Client’s prior consent. E. Compensation for Sales of Securities Tassel Capital does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Tassel Capital does not charge performance-based fees for its investment advisory services. The fees charged by Tassel Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Tassel Capital does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Tassel Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, and retirement plans. The amount of each type of Client is available on Tassel Capital’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Tassel Capital generally requires a minimum relationship size of $500,000 to effectively implement its investment process. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Tassel Capital primarily employs modern portfolio theory in developing investment strategies for its Clients. Tassel Capital also employs a fundamental analysis method in certain circumstances. Research and analysis from Tassel Capital 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. Modern portfolio theory is a theory of investment which attempts to maximize portfolio expected return for a given Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 8 amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Modern portfolio theory generally assumes that Clients are risk averse, which may result in lower returns on investments. Tassel Capital primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from Tassel Capital 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, Tassel Capital generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Tassel Capital 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, Tassel Capital 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. Tassel Capital will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 9 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 ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Tassel Capital or its owner. Tassel Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 121112. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Tassel Capital and its owner is to provide investment advisory services to its Clients. Neither Tassel Capital nor its Advisory Persons are involved in other business endeavors. Tassel Capital does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Tassel Capital has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Tassel Capital (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Tassel Capital and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Tassel Capital’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (704) 814- 6780. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 10 B. Personal Trading with Material Interest Tassel Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Tassel Capital does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Tassel Capital does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Tassel Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Tassel Capital requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). 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 Tassel Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Tassel Capital, or any Supervised Person of Tassel Capital, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Tassel Capital does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Tassel Capital to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Tassel Capital does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Tassel Capital does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Tassel Capital. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Tassel Capital may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Tassel Capital will generally recommend that Clients establish their account[s] at Fidelity Clearing & Custody Solutions and related entities of Fidelity Investments, Inc. (“Fidelity”). Fidelity (the “Custodian”) a FINRA-registered broker-dealer and member of SIPC and serve as the “qualified custodian” for the Client’s account[s]. Tassel Capital maintains an institutional relationship with the Custodian, whereby the Advisor receives certain economic benefits. 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. Tassel Capital does not participate in soft dollar programs sponsored or offered by any Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 11 broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Tassel Capital does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Tassel Capital will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Tassel Capital will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. 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. Tassel Capital will execute its transactions through the Custodian as authorized by the Client. Tassel Capital may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by William Ertel, Chief Compliance Officer of Tassel Capital. 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 Tassel Capital if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Tassel Capital Tassel Capital is a fee-only advisory firm, that is compensated solely by its Clients and not from any investment product. Tassel Capital does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Tassel Capital may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Tassel Capital may receive non-compensated referrals of new Clients from various third-parties. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 12 Participation in Institutional Advisor Platform (Fidelity) Tassel Capital has established an institutional relationship with Fidelity to assist the Advisor in managing Client accounts. Access to the Fidelity Platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients who maintain assets 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 Fidelity creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of a Custodian over another that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from Fidelity: 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; access to an electronic communication network for Client order entry and account information. B. Client Referrals from Promoters Tassel Capital does not compensate, either directly or indirectly, any affiliated or unaffiliated promoters, for Client referrals. Item 15 – Custody Tassel Capital 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 Tassel Capital 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 Tassel Capital 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 Tassel Capital to ensure accuracy, as the Custodian does not perform this review Money Movement Authorization - For instances where Clients authorize Tassel Capital to move funds between their accounts, Tassel Capital and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Tassel Capital generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Tassel Capital. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Tassel Capital will be in accordance with each Client's investment objectives and goals. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 13 Item 17 – Voting Client Securities Tassel Capital accepts proxy-voting responsibility for securities held in Client accounts when provided by the Client. The advisory agreement between Tassel Capital and the Client will generally specify whether or not Tassel Capital has the authority to vote proxies on behalf of a particular Client. Proxy Voting Policy and Procedures Tassel Capital shall vote proxies in the best interest of its Clients and shall not subrogate the Client interest to its own. Tassel Capital monitors corporate actions through the Custodian. Tassel Capital receives notice of upcoming proxy votes, meeting and record dates and other information on upcoming corporate actions by companies in which Tassel Capital Clients are shareholders. Clients may request a copy of Tassel Capital’s proxy voting records, free of charge, by contacting Tassel Capital. Conflicts of Interest in the Voting Process On occasion, a conflict of interest may exist between the Advisor and the client regarding the outcome of certain proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of the clients before we vote the proxy in question. Client Direction of Voting Although most of our Clients for whom we vote proxies authorize us to vote in accordance with our proxy voting policy, a Client may request that we vote its proxies in accordance with a different policy. We try to accommodate such requests. In addition, a Client may direct us to vote its securities in a particular way on a particular proposal and we will seek to do so, assuming timely receipt of the instruction. Item 18 – Financial Information Neither Tassel Capital, nor its management, have any adverse financial situations that would reasonably impair the ability of Tassel Capital to meet all obligations to its Clients. Neither Tassel Capital, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Tassel Capital is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 14 Form ADV Part 2B – Brochure Supplement for William B. Ertel, CFP®, CPA, PFS® Founder and Chief Compliance Officer Effective: July 14, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of William B. Ertel, CFP®, CPA, PFS® (CRD# 3057870) in addition to the information contained in the Tassel Capital Management (“Tassel Capital” or the “Advisor”, CRD# 121112) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Tassel Capital Disclosure Brochure or this Brochure Supplement, please contact us at (704) 814-6780. Additional information about Mr. Ertel 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# 3057870. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 15 Item 2 – Educational Background and Business Experience William B. Ertel, CFP®, CPA, PFS® born in 1970, is dedicated to advising Clients of Tassel Capital as the Founder and Chief Compliance Officer. Mr. Ertel earned a BA from Furman University in Mathematics and Accounting. Additional information regarding Mr. Ertel’s employment history is included below. Employment History: Founder and Chief Compliance Officer, Tassel Capital Management Investment Adviser Representative, Blue Ronald & Co LLC 06/2002 to Present 12/2001 to 08/2002 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Certified Public Accountant™ (“CPA”) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 16 all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours over a three-year period). Additionally, all American Institute of Certified Public Accountants™ (AICPA®) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. The vast majority of state boards of accountancy have adopted the AICPA’s® Code of Professional Conduct within their state accountancy laws or have created their own. Personal Financial Specialist™ (“PFS®”) The PFS® credential demonstrates that an individual has met the minimum education, experience, and testing required of a CPA® in addition to a minimum level of expertise in personal financial planning. To attain the PFS® credential, a candidate must hold an unrevoked CPA® license, fulfill 3,000 hours of personal financial planning business experience, complete 80 hours of individual financial planning CPE® credits, pass a comprehensive financial planning exam and be an active member of the AICPA®. A PFS® credential holder is required to adhere to AICPA’s® Code of Professional Conduct and is encouraged to follow AICPA’s® Statement on Responsibilities in Financial Planning Practice. To maintain their PFS® credential, the recipient must complete 60 hours of financial planning CPE® credits every three years. The PFS® credential is administered through the AICPA®. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Ertel. Mr. Ertel has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Ertel. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Ertel. However, we do encourage you to independently view the background of Mr. Ertel on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3057870. Item 4 – Other Business Activities Mr. Ertel is dedicated to the investment advisory activities of Tassel Capital’s Clients. Mr. Ertel does not have any other business activities. Item 5 – Additional Compensation Mr. Ertel is dedicated to the investment advisory activities of Tassel Capital’s Clients. Mr. Ertel does not receive any additional forms of compensation. Item 6 – Supervision Mr. Ertel serves as the Founder and Chief Compliance Officer of Tassel Capital. Mr. Ertel can be reached at (704) 814-6780. Tassel Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Tassel Capital. Further, Tassel Capital is subject to regulatory oversight by various agencies. These agencies require registration by Tassel Capital and its Supervised Persons. As a registered entity, Tassel Capital is subject to examinations by regulators, which may be announced Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 17 or unannounced. Tassel Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 18 Form ADV Part 2B – Brochure Supplement for Carlton S. Whitman, CFP® Financial Guide Effective: July 14, 2025 , (CRD# 6375955) in addition to the information contained in the Tassel Capital This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Carlton S. Whitman, CFP® Management (“Tassel Capital” or the “Advisor”, CRD# 121112) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Tassel Capital Disclosure Brochure or this Brochure Supplement, please contact us at (704) 814-6780. Additional information about Mr. Whitman 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# 6375955. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 19 Item 2 – Educational Background and Business Experience , born in 1989, is dedicated to advising Clients of Tassel Capital as a Financial Guide. Carlton S. Whitman, CFP® Mr. Whitman earned a Bachelor of Science, Business Administration, Major: Management from University of North Carolina at Charlotte in 2013. Additional information regarding Mr. Whitman’s employment history is included below. Employment History: Financial Guide, Tassel Capital Management Trading/Service Representative, Wells Fargo Advisors Client Service Specialist, SunTrust Bank 02/2015 to Present 06/2014 to 02/2015 01/2013 to 06/2014 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 20 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Whitman. Mr. Whitman has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Whitman. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Whitman. However, we do encourage you to independently view the background of Mr. Whitman on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6375955. Item 4 – Other Business Activities Mr. Whitman is dedicated to the investment advisory activities of Tassel Capital’s Clients. Mr. Whitman does not have any other business activities. Item 5 – Additional Compensation Mr. Whitman is dedicated to the investment advisory activities of Tassel Capital’s Clients. Mr. Whitman does not receive any additional forms of compensation. Item 6 – Supervision Mr. Whitman serves as a Financial Guide of Tassel Capital and is supervised by William Ertel, the Chief Compliance Officer. Mr. Ertel can be reached at (704) 814-6780. Tassel Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Tassel Capital. Further, Tassel Capital is subject to regulatory oversight by various agencies. These agencies require registration by Tassel Capital and its Supervised Persons. As a registered entity, Tassel Capital is subject to examinations by regulators, which may be announced or unannounced. Tassel Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 21 Form ADV Part 2B – Brochure Supplement for Bradley P. Kendall, CFP® Financial Planner Effective: July 14, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Bradley P. Kendall (CRD# 7166341) in addition to the information contained in the Tassel Capital Management (“Tassel Capital” or the “Advisor”, CRD# 121112) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Tassel Capital Disclosure Brochure or this Brochure Supplement, please contact us at (704) 814-6780. Additional information about Mr. Kendall 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# 7166341. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 22 Item 2 – Educational Background and Business Experience Bradley P. Kendall, CFP®, born in 1996, is dedicated to advising Clients of Tassel Capital as a Financial Planner. Mr. Kendall earned a degree in Financial Management from Clemson University in 2019. Additional information regarding Mr. Kendall’s employment history is included below. Employment History: Financial Planner, Tassel Capital Management Financial Services Representative, New York Life Insurance Company Business Operations Intern, Quicken Loans Mortgage Services Donor Relations Intern, Gethsemane Garden Christian Centre 10/2020 to Present 08/2019 to 09/2020 05/2018 to 08/2018 05/2017 to 08/2017 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real-world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 23 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Kendall. Mr. Kendall has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Kendall. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Kendall. However, we do encourage you to independently view the background of Mr. Kendall on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7166341. Item 4 – Other Business Activities Mr. Kendall is dedicated to the investment advisory activities of Tassel Capital’s Clients. Mr. Kendall does not have any other business activities. Item 5 – Additional Compensation Mr. Kendall is dedicated to the investment advisory activities of Tassel Capital’s Clients. Mr. Kendall does not receive any additional forms of compensation. Item 6 – Supervision Mr. Kendall serves as a Financial Planner of Tassel Capital and is supervised by William Ertel, the Chief Compliance Officer. Mr. Ertel can be reached at (704) 814-6780. Tassel Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Tassel Capital. Further, Tassel Capital is subject to regulatory oversight by various agencies. These agencies require registration by Tassel Capital and its Supervised Persons. As a registered entity, Tassel Capital is subject to examinations by regulators, which may be announced or unannounced. Tassel Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 24 Form ADV Part 2B – Brochure Supplement for Susan J. Kelly, CFP® Financial Planner Effective: July 14, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Susan J. Kelly, CFP®, (CRD# 8108284) in addition to the information contained in the Tassel Capital Management (“Tassel Capital” or the “Advisor”, CRD# 121112) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Tassel Capital Disclosure Brochure or this Brochure Supplement, please contact us at (704) 814-6780. Additional information about Ms. Kelly is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 8108284. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 25 Item 2 – Educational Background and Business Experience Susan J. Kelly, CFP®, born in 1979, is dedicated to advising Clients of Tassel Capital as a Financial Planner. Ms. Kelly earned a J.D. from the University of North Carolina in 2004. Ms. Kelly also earned a B.S. of Business Management from Wake Forest University in 2001. Additional information regarding Ms. Kelly’s employment history is included below. Employment History: Tassel Capital Management, Inc - Financial Planner - Paraplanner 01/2025 to Present 09/2017 to 12/2024 CERTIFIED FINANCIAL PLANNER® Professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the Client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 26 professional's services. A Client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the Client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Ms. Kelly. Ms. Kelly has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Kelly. 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 Ms. Kelly. However, we do encourage you to independently view the background of Ms. Kelly on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 8108284. Item 4 – Other Business Activities Ms. Kelly is dedicated to the investment advisory activities of Tassel Capital’s Clients. Ms. Kelly does not have any other business activities. Item 5 – Additional Compensation Ms. Kelly is dedicated to the investment advisory activities of Tassel Capital’s Clients. Ms. Kelly does not receive any additional forms of compensation. Item 6 – Supervision Ms. Kelly serves as a Financial Planner of Tassel Capital and is supervised by William Ertel, the Chief Compliance Officer. Mr. Ertel can be reached at (704) 814-6780. Tassel Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Tassel Capital. Further, Tassel Capital is subject to regulatory oversight by various agencies. These agencies require registration by Tassel Capital and its Supervised Persons. As a registered entity, Tassel Capital is subject to examinations by regulators, which may be announced or unannounced. Tassel Capital is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 27 Privacy Policy Effective: July 14, 2025 Our Commitment to You Tassel Capital Management (“Tassel Capital” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Tassel Capital (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Tassel Capital does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account SMS Messaging The Advisor’s SMS messaging provides the Client with timely and relevant communications directly from the Advisor. Client’s can expect to receive periodic messages that may include notifications about upcoming meetings, responses to inquiries, and important account-related information. These messages are sent via an SMS application, where all sensitive data is delivered securely, to maintain the confidentiality and integrity of the Client’s data. Please note that the frequency and content of these messages will be related to the services to the Client. 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 Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 28 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. 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 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. No Not Shared Yes Yes No Not Shared Marketing Purposes Tassel Capital does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Tassel Capital or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Tassel Capital does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (704) 814-6780. Tassel Capital Management 1220 Mann Drive, Suite 100, Matthews, NC 28105 Phone: (704) 814-6780 http://www.tasselcapital.com/ Page 29