TENCAP WEALTH COACHING

Cover Page - Item 1 Tencap Wealth Coaching 1314 West 11400 South, Suite 201 South Jordan, UT 84095 Tel: 801-337-5032 Email: greg@tencap.com Form ADV Part 2A Brochure March 20, 2026 Tencap Wealth Coaching is a registered investment adviser. An "investment adviser" means any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Tencap Wealth Coaching. If you have any questions about the contents of this brochure, please contact us at 801-337- 5032. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Tencap Wealth Coaching is available on the SEC’s website at Additional www.adviserinfo.sec.gov. The firm's CRD/IARD number is 166130.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 2 Material Changes - Item 2 On February 25, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of approximately $285,025,351, and non-discretionary assets under management of approximately $0. In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item 8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct Indexing, Securities Backed Lines of Credit (SBLOCs), Political Risk and Artificial Intelligence ("AI") Risk.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 3 Table of Contents - Item 3 Contents Cover Page - Item 1 ................................................................................................................................... 1 Material Changes - Item 2 ......................................................................................................................... 2 Table of Contents - Item 3 ........................................................................................................................ 3 Advisory Business - Item 4 ........................................................................................................................ 4 Fees and Compensation - Item 5 .............................................................................................................. 9 Performance-Based Fees and Side-By-Side Management - Item 6 ........................................................ 11 Types of Clients - Item 7.......................................................................................................................... 11 Methods of Analysis, Investment Strategies and Risk of Loss - Item 8................................................... 12 Disciplinary Information - Item 9 ............................................................................................................ 16 Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 16 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 17 Brokerage Practices - Item 12 ................................................................................................................. 18 Review of Accounts - Item 13 ................................................................................................................. 21 Client Referrals and Other Compensation - Item 14 .............................................................................. 22 Custody - Item 15 .................................................................................................................................... 23 Investment Discretion - Item 16 ............................................................................................................. 23 Voting Client Securities - Item 17 ........................................................................................................... 24 Financial Information - Item 18 .............................................................................................................. 24 Requirements of State-Registered Advisers - Item 19 ............................................................................ 24  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 4 Advisory Business - Item 4 Firm Description Tencap Wealth Coaching, LLC, doing business as Tencap Wealth Coaching (formerly Tencap, LLC), (“Tencap”) was founded in 2012 and became registered to offer advisory services in 2013. The principal owner of Tencap Wealth Coaching is Kerry Park Family Limited Partnership. Gregory D. Black is the Chief Compliance Officer. The following paragraphs describe our services and fees. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly licensed or registered as investment adviser representatives. Types of Advisory Services ASSET MANAGEMENT We primarily offer discretionary portfolio management services to our clients. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you prior to each transaction. These decisions would be made based upon your stated investment objectives. If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your portfolio. Simply provide us with your restrictions or guidelines in writing. In limited cases, and only in the firm’s discretion, we may accept non-discretionary portfolio management engagements. Non-discretionary portfolio management service means that we must obtain your approval prior to placing any transactions in your account. Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to assist you with the management of your portfolio, an Associated Person of Tencap will meet with you and gather information about your financial situation, investment objectives, and any reasonable restrictions you would like to impose on the management of the account. The information we gather will help us implement an asset allocation strategy that will be specific to your needs and goals. All accounts are managed in accordance with the client’s investment needs. Investments may include various types of securities such as equities, Exchange Traded Funds (ETFs), mutual funds, corporate debt securities, commercial paper, certificates of deposit, municipal securities, and U.S. Government securities. Other types of investments may also be recommended where such investments are appropriate based on the client’s stated goals and objectives. Investments and allocations are determined and based upon the client’s predefined objectives, risk tolerance, time horizon, financial horizon, financial information, and other various suitability factors. Further restrictions and guidelines imposed by the client may affect the composition and performance of a client’s portfolio. For these reasons, performance of the portfolio may not be identical to other clients of Tencap. On an ongoing basis, Tencap reviews the client’s financial circumstances and investment objectives, and instructs the sub adviser to make the necessary adjustments to the client’s portfolio. Clients are advised to provide the firm with prompt notice of any changes in their personal financial circumstances, investment objectives, goals, and tolerance for risk. However, Tencap will contact the client at least annually to determine whether there have been any changes in the client's personal financial circumstances, investment objectives, and tolerance for risk. Our asset allocation and advisory services are offered directly by our firm or in conjunction with a sub-adviser. Where we use the services of a sub-adviser, the sub-adviser assists our firm with back-office support, trading, report preparation, and billing. The sub-adviser will place client portfolios in their proprietary models, along with models created by other investment advisers. All clients will be provided with a current copy of the sub-adviser’s  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 5 Form ADV Part 2 Brochure at the inception of services. This document provides important disclosures about the sub-adviser’s services, portfolio models, fees, conflicts of interest, disciplinary history (if any), and other important information that would help clients understand the scope of services provided by them. THE CO-ADVISOR Note: Our asset management services are offered directly by our firm or in conjunction with a co-adviser. As of October 2025, co-advisory services are no longer offered to new clients of Tencap. The co-adviser selected by our firm is Matson Money, Inc. (“MM”). When determining the MM platform to recommend to clients, the client’s best interest will be the main determining factor of Tencap. Tencap acts as the co-advisor between the client and MM in return for the advisory fees collected from the accounts by MM. Tencap is responsible for: • Helping the client complete the necessary paperwork of MM and the custodian; • Updating MM with any changes in client status which are provided to Tencap by the client; • Reviewing the quarterly statements provided by MM and the custodian; and • Delivering the Form ADV Part 2, Privacy Notice and Written Disclosure Statement of MM to the client. Matson Fund Platform The Matson Fund Platform is a “fund of funds” that invests primarily in shares of other mutual funds pursuant to exemptive relief from the SEC. The Funds are designed to target specified percentages of certain asset classes in each Fund’s applicable investment category to seek maximum portfolio diversification, enhanced return opportunities and diminished portfolio volatility. Clients of Tencap complete a questionnaire, risk analysis and portfolio review in order for MM to assign each Client account to one of seven “model portfolios,” with target underlying asset allocations. Each model portfolio corresponds to some combination of investments in the Matson Funds. Clients determine their investment objectives and most appropriate combination through the Questionnaire process with Tencap, but are not otherwise permitted to impose restrictions on their accounts given that the accounts are invested in mutual funds subject to their own inherent investment restrictions. Clients are not required to accept the recommendation to use MM given by Tencap and have the option to receive investment advice through other money managers of their choosing. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, a thorough review of all applicable topics, including but not limited to, the following will be reviewed: Retirement Planning Succession Planning Education Planning Retirement planning services typically include projections of your likelihood of achieving your financial goals, with financial independence usually being the primary objective. For situations where projections show less than the desired results, a recommendation may include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. Succession planning is a process for identifying and developing new leaders who can replace old leaders when they leave, retire or die. Succession planning increases the availability of experienced and capable employees that are prepared to assume these roles as they become available. Advice involving college funding may include projecting the amount that will be needed to achieve post-secondary education funding goals, along with savings strategies and the “pros-and-cons” of various college savings vehicles that are available. We are also available  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 6 Legacy Planning to review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren, if appropriate. This service is designed to help client’s get all of their financial documents organized in orderly fashion and to make sure their final wishes and instructions are provided to key people whether they are family or trusted advisors or friends. Process to identify and evaluate insurance needs of client. Insurance Planning Investment Planning Investment consultation services often involve providing information on the types of investment vehicles available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and portfolio design, as well as limited assistance if your investment account if it is maintained at another broker/dealer or custodian. Advice on personal budgeting, helping put plan into action. Steps: Budget Planning 1. Calculate expenses 2. Determine income 3. Set savings and debt payoff goals 4. Record spending and track progress Personal Financial Planning Tax Planning Major Purchase Planning Divorce Planning Debt Management Planning Business Exit Planning Client receives budget change proposals and recommendations. Typically includes projections of the likelihood of achieving financial goals, with financial independence usually being the primary objective. For situations where projections show less than the desired results, a recommendation may include showing the impact on those projections by making changes to certain variables (e.g. working longer, saving more, spending less, taking more risk with investments). Advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during retirement years. Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, recommendations may be offered as to which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. Analysis and recommendations for major purchases or expenses. Discussing pros and cons of paying cash or using credit to purchase items that are in addition to normal living expenses. Separation or divorce can have a major impact on your goals and plans. We will work with you to help you gain an understanding of your unique situation and provide you with a realistic financial picture so that you are in a better situation to communicate with legal counsel, a mediator or soon to be ex-spouse. We can assist in the completion of cash flow and net worth projections, budgetary analysis, division of property, as well as help you to understand what the consequences and/or benefits are involving a settlement. A review of your income and expenses will be conducted to determine your current surplus or deficit. Based upon the results, we will provide advice on prioritizing how any surplus should be used, or how to reduce expenses if they exceed your income. In addition, advice on the prioritization of which debts to repay may be provided, based upon such factors as the debt’s interest rate and any income tax ramifications. Recommendations may also be made regarding the appropriate level of cash reserves for emergencies and other financial goals. These recommendations are based upon a review of cash accounts (such as money market funds) for such reserves and may include strategies to save desired reserve amounts. Advice on possible scenarios to exit business. Provide recommendations for exit plan, such as: 1. How to close down a non-profitable business 2. Execute an investment or business venture when profit objectives are met  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 7 3. Close down a business in the event of a significant change in market conditions 4. Sell an investment or a company 5. Sell an unsuccessful company to limit losses Reduce ownership in a company or give up control Advice on personal budgeting, helping put plan into action. Steps: Cash Flow Analysis 5. Calculate expenses 6. Determine income 7. Set savings and debt payoff goals 8. Record spending and track progress Client receives budget change proposals and recommendations. If a conflict of interest exists between the interests of Tencap and the interests of the Client, the client is under no obligation to act upon Tencap’s recommendation. If the client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through Matson Money, with whom Tencap is a secondary advisor. Tencap Legacy LLC, the insurance entity owned by Gregory D. Black, or any other independent insurance agent affiliated with Tencap. Financial plans will be completed and delivered inside of thirty (30) days. Clients may terminate advisory services with five (5) days written notice. When insurance is a part of the financial plan, it should be noted, the firm’s Managing Member, Gregory D. Black is an independent insurance agent. Please see the “External Compensation for the Sale of Investments to Clients” section in Item 5 below for more information about the sale of insurance products and associated conflicts of interest. RETIREMENT PLAN CONSULTING SERVICES Tencap provides several types of retirement plan consulting services. While the primary clients for these services will be pension, profit sharing and 401(k) plans, Tencap will also offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Services are comprised of the following components. Clients may choose to use any or all of the following services: • Assistance with the development, review and revision of an Investment Policy Statement (“IPS”) as requested. • Assistance with recommendations regarding menu diversification, and non-discretionary model portfolios. • Meeting with Client on a periodic basis to discuss reports and investment decisions and to make • recommendations. Performance of an analysis of the fees and expenses associated with the investments, and the service providers, and recommendation of changes when warranted. • Assistance with the selection of a qualified default investment alternative (“QDIA”) and determination of the continuing suitability of a QDIA. • Assistance with the monitoring of investment options by preparing quarterly reports that document investment performance, consistency of fund management, and conformance to any guidelines set forth in the IPS and will notify you with any recommendations. • Ongoing and continuous discretionary investment management with respect to the asset classes and investments for the Plan in accordance with the Plan’s investment policies and objectives. This service is described in more detail in the Portfolio Management Services section above. Selection of a broad range of investment options consistent with ERISA and the regulations thereunder. • These services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under ERISA. Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below).  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 8 The services we provide to your Plan are described above, and in the service agreement that you have previously signed. Our compensation for these services is described below, in Item 5, and also in the Pension Consulting Agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. Other pension consulting services are available on request. All of our pension consulting services, whether general or customized, will be outlined in an Agreement that shows the services that will be provided and the fees that will be charged for those services. Tencap is registered as an investment advisor and represents that it is not subject to any disqualification as set forth in Section 411 under the Employee Retirement Income Security Act (“ERISA”). To the extent Tencap performs Fiduciary Services, Tencap is acting as a fiduciary of the Plan as defined in Section 3(21) or Section 3(38) under ERISA. Tencap may also perform the following Non-Fiduciary services: • Assistance with the education of the participants in the Plan about general investment principles. Client understands that Tencap’s assistance in participant investment education shall be consistent with and within the scope of the definition of investment education of Department of Labor Interpretive Bulletin 96-1. • Assistance with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Tencap may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Tencap and Client. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Client Agreements may not be assigned without written client consent. Wrap Fee Programs Tencap does not sponsor any wrap fee programs. Client Assets Under Management Tencap has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $285,025,351 $0 December 31, 2025  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 9 Fees and Compensation - Item 5 Method of Compensation and Fee Schedule ASSET MANAGEMENT On an annualized basis, our fees for asset management services, subject to negotiation, are based on the following tiered/blended fee schedule. Since the fee is negotiable, the exact fee paid by you will be stated in the advisory agreement signed by you and us: Billable Assets Under Management Total Annual Fee First $500,000 1.15% Next $500,000 1.05% Next $3,000,000 0.75% Over $4,000,000 0.50% The annual fee is billed monthly or quarterly, in advance or in arrears depending on the arrangement negotiated with each client. Fees will be assessed pro rata in the event the Agreement is executed at any time other than the first day of a billing period. We may deduct the fee from a single, client-designated account to facilitate billing. Accounts within the same household custodied at the same custodian may be combined for a reduced fee. Clients should note that sub-advisers charge a separate fee that is disclosed to the client on the sub-adviser’s disclosure document. These fees are separate from and in addition to the fee charged by Tencap. Tencap considers cash to be an asset class, and as such, cash held in investment accounts is included in fee calculations. Also, to be noted, at times fees will exceed the money market yield. If the Account does not contain sufficient funds to pay advisory fees, Tencap has authority to sell or redeem securities in sufficient amounts to pay advisory fees. Lower fees for comparable services may be available from other sources. Fees for asset management services are deducted from a designated Client account to facilitate billing. Please see Item 15 for more information regarding direct deduction of fees from Client’s accounts. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days of signing the agreement, Clients may cancel by providing written notice to Tencap and Tencap may terminate advisory services with thirty (30) days written notice to Client. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. The balance of any prepaid, unearned fees (if any) will be refunded to the client. Client shall be given thirty (30) days prior written notice of any increase in fees. CO-ADVISOR FEES Tencap acts as a co-advisor with Matson Money, Inc. (“MM”) (CRD #110425/SEC #801-40176) to manage client accounts. In such cases, MM exercises sole discretionary authority over the account and deducts Tencap’s advisory fees on behalf of our firm. MM does not charge a direct asset management fee to the client. However, MM is compensated by collecting a fee in the form of its proprietary mutual funds’ expense ratios. These fees are disclosed to all clients at the inception of services. A complete description of MM’s asset management programs and services, account minimums, the amount of total fees, payment structure, termination provisions, conflicts of interest and other aspects of each program are detailed and disclosed in MM’s Form ADV Part 2A or other applicable disclosure documents provided to clients at the inception of services.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 10 FINANCIAL PLANNING Tencap charges a negotiable fixed fee of up to $10,000 for financial planning services. The fee will be determined based on the complexity of the client’s current investments and the number of areas to be reviewed. The areas of review may include, but are not limited to retirement planning, investment planning, budgeting, estate planning, tax planning, and insurance planning. Tencap reserves the right to waive the financial planning fee on a case-by-case basis. Prior to engaging Tencap for financial planning services, the client will be required to enter into a financial planning agreement with our firm. The Agreement will set forth the terms and conditions of the engagement and describe the scope of the services to be provided and the fee that is due from the client. The fee is payable at the inception of services and plans will be completed within six months of engagement. Either party may terminate the financial planning agreement by written notice to the other. In the event the client terminates Tencap’s financial planning services, the balance of any prepaid, unearned fees (if any) will be refunded to the client. PENSION CONSULTING SERVICES FEES The fees and compensation charged by Tencap is negotiated independently with each Plan Sponsor in order to consider the varying, unique characteristics or requirements of each plan. Primary determinants of the negotiated fee may include but are not limited to the: Special plan sponsor considerations or requirements. • Amount of plan assets, • Number of employees / participants, • Number of plan sponsor locations, and • Delivery of compensation or fees to Tencap is dependent upon on the invoicing or fee assessment frequency (monthly, quarterly) and policies (“arrears” or “in advance”) of the Plan Provider/Platform utilized by the Plan Sponsor. The exact fee and fee payment method will be clearly listed in the Agreement signed by the client and the Tencap. Either party to the Agreement may terminate the agreement upon 30-days’ written notice to the other party. The fees will be prorated for the period in which the termination notice is given, and any prepaid, unearned fees will be refunded to the client. Client Payment of Fees Fees for asset management services are deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans are billed at the commencement of the planning process. Clients will be billed in accordance with Matson Money, Inc.’s fee schedule which will be disclosed to the client’s prior to signing an agreement. Additional Client Fees Charged Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. Tencap does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to Tencap. For more details on the brokerage practices, see Item 12 of this brochure.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 11 Prepayment of Client Fees Tencap does not require any prepayment of fees of more than $1,200 per Client and six months or more in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Tencap. External Compensation for the Sale of Investments to Clients Certain Executive officers and other Associated Persons of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by these persons are separate from and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by Associated Persons are intended to complement our advisory services. However, this practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance services. Clients who do choose to purchase insurance services are under no obligation to use our licensed Associated Persons and may use the insurance brokerage firm and agent of their choice. Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. Performance-Based Fees and Side-By-Side Management - Item 6 Fees are not based on a share of the capital gains or capital appreciation of managed securities. Tencap does not use a performance-based fee structure and therefore does not engage in side-by-side management. Types of Clients - Item 7 Tencap generally provides investment advice to individuals, high net worth individuals, corporations, and institutions. Client relationships vary in scope and length of service.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 12 Account Minimums Tencap requires a minimum of $300,000 to open and maintain an account. In certain instances, the minimum account size may be lowered or waived. Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 Methods of Analysis Security analysis methods may include fundamental analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Tencap is a secondary advisor of Matson Money, Inc. and utilizes MM’s services based on the portfolios offered, firm’s management style, its investment portfolio managers, and the additional services provided such as Morningstar reports and portfolio analysis reports. MM may use various methods of analysis to determine the proper strategy for the client referred and these will be disclosed in MM Form ADV Part 2. Investing in securities involves risk of loss that clients should be prepared to bear. Asset allocation models are developed by the sub-adviser or other third-party model providers are developed in accordance with investment programs developed by these entities. Tencap will not implement its own methods of analysis. Clients should refer to the relevant model provider’s Form ADV Part 2 Brochures or other disclosure documents for more information about the methods of analysis used by those firms. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. In developing a financial plan for a client, Tencap’s analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the client’s specific situation. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to Tencap. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with Tencap: • Market Risk: The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 13 • • • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • • • • • • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Investment Companies Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. Foreign Securities Risk: Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. Long-term purchases: Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 14 • • provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. Foreign Investment Risk: Investments in foreign securities may be riskier than U.S. investments because of factors such as, unstable international, political and economic conditions, currency fluctuations, foreign controls on investment and currency exchange, foreign governmental control of some issuers, potential confiscatory taxation or nationalization of companies by foreign governments, withholding taxes, a lack of adequate company information, less liquid and more volatile exchanges and/or markets, ineffective or detrimental government regulation, varying accounting standards, political or economic factors that may severely limit business activities, and legal systems or market practices that may permit inequitable treatment of minority and/or non-domestic investors. Investments in emerging markets may involve these and other significant risks such as less mature economic structures and less developed and more thinly-traded securities markets. All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. The specific risks associated with financial planning include: • Risk of Loss o Client fails to follow the recommendations of Tencap resulting in market loss o Client has changes in financial status or lifestyle and therefore plan recommendations are no longer valid The risks associated with utilizing TPM’s include: • Manager Risk o TPM fails to execute the stated investment strategy • Business Risk o TPM has financial or regulatory problems o The specific risks associated with the portfolios of the TPM’s which is disclosed in the TPM’s Form ADV Part 2. Margin Transactions: margin strategies allow an investor to purchase securities on credit and to borrow on securities already in their custodial account. Interest is charged on any borrowed funds for the period that the loan is outstanding. When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account, you will be required to open a margin account, which will be carried by the broker-dealer of your account. The securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a brokerage firm is required to take action, such as issue a margin call and/or sell securities or other assets in your accounts, in order to maintain necessary level of equity in the account. It is important that you fully understand the risks involved in trading securities on margin, which are applicable to any margin account that you may maintain, including any margin Account that may be established as a part of our advisory services and held by your broker-dealer. These risks include the following: • • • • • You can lose more funds than you deposit in your margin account. The broker-dealer can force the sale of securities or other assets in your account. The broker-dealer can sell your securities or other assets without contacting you. You may not be able to choose which securities or other assets in your margin account are liquidated or sold to meet a margin call. The broker-dealer may move securities held in your cash account to your margin account and pledge the transferred securities. You may not be entitled to an extension of time on a margin call. •  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 15 Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing can provide a more tax efficient means of investing, and allows for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if a client does not take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on specific tax, Environmental, Social, and Governance or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of the account and the number of securities in the index the account seeks to replicate also limit the ability of the account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index and can cause a portfolio to underperform the index, including as a result of customization. Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on investment model portfolios and strategies developed by the third-party investment advisers and their portfolio managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks associated with investing with a third party is that while a particular third party may have demonstrated a certain level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do not control the underlying investments in third party model portfolios, there is also a risk that a third party may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a consistent level of performance and success over time. A third party’s past performance is not a guarantee of future results and certain market and economic risks exist that may adversely affect an account’s performance that could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment strategies, methods of analysis, and associated risks. Securities Backed Lines of Credit (SBLOCs): SBLOCs are non-purpose loans where you pledge assets in your account as collateral in return for a loan. The loan proceeds can be used for purposes other than to purchase or trade securities. Depending on your objectives, we can help you apply for a SBLOC. This can be a strategic alternative to liquidating assets to pay for unexpected expenses, a business opportunity, or a personal goal, any of which could trigger capital gain taxes. While we do not receive a fee for arranging these loans, our assistance in this process presents a conflict of interest, as we have an incentive for you to maintain these assets in your account instead of liquidating them, as liquidation could decrease the asset-based fees that we earn for managing your account. To address this conflict, we only make recommendations to obtain such loans when we believe obtaining a SBLOC is in the best interests of clients. Clients should note that they retain the ultimate decision to obtain such loans. The following are some of the primary risks associated with obtaining a SBLOC: • • • • • Interest rate payments on the principal balance of the loan are not fixed and may increase; If the value of the securities pledged as collateral decrease, you will be liable for any deficiency; The lender can force the sale or liquidation of securities held as collateral without contacting you in advance to meet collateral requirements and you are not entitled to choose which securities are liquidated or sold; You are only entitled to draw on the line to the extent there is credit availability; and There may be additional risks when money funds or similar investments may produce less interest income or other yield than the interest you are paying on the loan. We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or non- purpose loan. While we can assist in the application process, we are not involved in the approval process.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 16 Political Risk: Each administration presents its own set of policy risks that could impact investors. One of the policy tools that an administration can implement is the imposition of tariffs, or the threats thereof. The scope, implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that rely on imported raw material or that have heavily integrated cross-border manufacturing practices may be most impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed, which could further impact industries and products. Tariffs in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic growth and add to inflation, which can lead to rising interest rates. Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning, probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools are also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex, and are known to have been flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in the firm’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, the firm may rely on AI Tools developed by third parties, and the firm has limited control over the accuracy and completeness of such AI Tools. Clients who do not want us to record their meetings have the option to opt out at the time of the meeting. Disciplinary Information - Item 9 Criminal or Civil Actions The firm and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings The firm and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings The firm and its management have not been involved in legal or disciplinary events related to past or present investment clients. Other Financial Industry Activities or Affiliations - Item 10 Broker-Dealer or Representative Registration Tencap has no representatives or employees who are registered representatives of a broker dealer. Futures or Commodity Registration Neither Tencap nor its employees are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Tencap Legacy, LLC is an insurance agency related to our firm through common control and ownership. Gregory D. Black and other Associated persons of our firm are independent licensed insurance agents with Tencap Legacy, LLC or other insurance agencies. From time to time, clients will be offered insurance services. These practices represent conflicts of interest because it gives Tencap an incentive to recommend products or services based on  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 17 the compensation received rather than the client’s needs. This conflict is mitigated by the fact that the clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another insurance agent. Please see the “External Compensation for the Sale of Investments to Clients” section in Item 5 above for more information about the sale of insurance products and associated conflicts of interest. In addition, Mr. Black is the General Partner of the Kerry Park Family Limited Partnership and the manager of Tencap Real Estate LLC. He spends approximately 1% of his time on each of these activities. These are not a conflict of interest as no Clients of the RIA firm will be solicited for these services or vice versa. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Tencap uses the co-advisory services of Matson Money, Inc. (“MM”) to manage certain client accounts. MM does not charge a direct asset management fee to the client. However, MM is compensated by collecting a fee in the form of its proprietary mutual funds’ expense ratios. These fees are disclosed to all clients at the inception of services. Tencap does not share in the fees charged by MM. However, for co-advisory relationships, MM acts as a payment agent for Tencap and deducts Tencap’s customary asset management fee directly from client account on behalf of Tencap. This relationship creates a conflict of interest because we have an incentive to recommend MM based on the fee deduction service they provide us for no additional cost to us. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 Code of Ethics Description The employees of Tencap have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Tencap employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of Tencap. The Code reflects Tencap and its supervised persons’ responsibility to act in the best interest of their client. One area which the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. Tencap’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of Tencap may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Tencap’s Code is based on the guiding principle that the interests of the client are our top priority. Tencap’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests over the interests of either employees or the company. The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to clients, or who have access to such recommendations that are non-public. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 18 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Tencap and its employees do not recommend securities to clients in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Tencap and its employees may buy or sell securities that are also held by clients. Conflicts of interest such as front running may occur. In order to mitigate the conflicts, employees are required to disclose all reportable securities transactions as well as provide Tencap with copies of their brokerage statements. The Chief Compliance Officer of Tencap is Gregory D. Black, CFP®, ChFC®. He reviews all employee trades each quarter. The personal trading reviews helps mitigate that the personal trading of employees does not affect the markets and that clients of the firm have received preferential treatment over employee trade. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Tencap does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, employees may buy or sell securities at the same time they buy or sell securities for clients and may cause a conflict of interest such as front-running. In order to mitigate conflicts of interest, employees are required to disclose all reportable securities transactions as well as provide Tencap with copies of their brokerage statements. The Chief Compliance Officer of Tencap is Gregory D. Black, CFP®, ChFC®. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment over employee transactions. Brokerage Practices - Item 12 Factors Used to Select Broker-Dealers for Client Transactions Tencap will require the use of a particular custodial broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by Tencap, and involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the custodial broker-dealer, the value of an ongoing relationship and the financial strength and stability of the custodial broker-dealer. Tencap will select appropriate custodial broker-dealer based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. Tencap relies on its custodial broker-dealer to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by Tencap. Tencap does not receive any portion of the trading fees. At this time, Tencap has institutional custodial relationships with Altruist Financial LLC (Altruist), a FINRA- registered broker-dealer, member SIPC, and Charles Schwab & Co., Inc. (Schwab), a FINRA-registered broker- dealer, member SIPC. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like Tencap. Tencap is independently owned and operated and not affiliated with Altruist or Schwab. One of these qualified custodians will hold your assets in a brokerage account and will buy and sell securities in your account(s) upon Tencap’s instructions. While Tencap recommends that you use Altruist or Schwab as custodian/broker, you will decide whether to do so, and you will open your account with Altruist or Schwab by entering into an account agreement directly with them. Tencap does not open the account for you.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 19 How Tencap Selects Brokers/Custodians When considering whether the terms that a broker-dealer/custodian provides are, overall, most advantageous to you when compared with other available providers and their services, Tencap takes into account a wide range of factors, including: • • • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) Capability to execute, clear, and settle trades (buy and sell securities for your account) Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist Tencap in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices Prior service to Tencap and its clients Services delivered or paid for by Schwab • Reputation, financial strength, security, and stability • • • Availability of other products and services that benefit Tencap, as discussed below Research and Other Soft-Dollar Benefits While Tencap has no formal soft dollar program in which soft dollars are used to pay for third-party services, Tencap will receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions. There can be no assurance that any particular client will benefit from such benefits whether or not the client’s transactions paid for it, and Tencap does not seek to allocate benefits to client accounts proportionate to any benefits received by a particular account or group of accounts. Tencap benefits by not having to produce or pay for the research, products, or services, and Tencap will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that Tencap’s acceptance of additional benefits can result in higher commissions charged to the client. Although the following products and services are not purchased with “soft dollar” credits, Tencap will receive certain economic benefits (soft dollar benefits) from broker-dealers/custodians in the form of access to institutional brokerage and support services at no additional cost or discounted cost. Products and Services Available to Tencap from Schwab Schwab Advisor Services™ (“SAS”) is Schwab’s business serving independent investment advisory firms like Tencap. SAS provides Tencap clients and Tencap with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through Tencap. Schwab also makes available various support services. Some of those services help Tencap manage or administer its clients’ accounts, while others help Tencap manage and grow its business. Schwab’s support services are generally available on an unsolicited basis (Tencap does not have to request them) and at no charge to Tencap. Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which Tencap might not otherwise have access or that would require a significantly higher minimum initial investment by Tencap clients. Schwab’s services described in this paragraph generally benefit you and your account.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 20 Services that Do Not Directly Benefit You: Schwab also makes available to Tencap other products and services that benefit Tencap but do not directly benefit Tencap clients or clients’ accounts. These products and services assist Tencap in managing and administering Tencap clients’ accounts and operating the firm. The products and services include investment research, both Schwab’s own and that of third parties. Tencap uses this research to service all or a substantial number of Tencap clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: provide access to client account data (such as duplicate trade confirmations and account statements), facilitate trade execution and allocate aggregated trade orders for multiple client accounts, provide pricing and other market data, facilitate payment of Tencap fees from clients’ accounts, and assist with back-office functions, recordkeeping, and client reporting. • • • • • Services that Generally Benefit Only Tencap: Schwab also offers other services intended to help Tencap manage and further develop its business enterprise. These services include: educational conferences and events, consulting on technology and business needs, consulting on legal and compliance-related needs, publications and conferences on practice management and business succession, access to employee benefits providers, human capital consultants, and insurance providers, recruiting and custodial search consulting. • • • • • • marketing consulting and support, and • Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Tencap. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides Tencap with other benefits, such as occasional business entertainment for Tencap personnel. If you did not maintain your account with Schwab, Tencap would be required to pay for those services from Tencap’s resources. Products and Services Available to Tencap from Altruist Tencap receives certain economic benefits from Altruist in the form of access to its institutional brokerage, trading, custody, reporting and related services. Altruist also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Below is a detailed description of these support services: Services that Benefit You: Altruist’ provides us with access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Altruist include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Altruist’ services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You: Altruist also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Altruist’ own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Altruist. In addition to investment research, Altruist also makes available software and other technology that: provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. • • • • •  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 21 Services that Generally Benefit Only Us: Altruist’s support services include payments to or reimbursement for the cost of certain technology solutions to help facilitate Tencap’s practices and to streamline our operations. The payments may be substantial and are based on Tencap clients adding, transferring to, and maintaining a certain amount of assets on Altruist’s platform. These benefits provided to Tencap will not directly benefit client accounts. The fees Tencap charges will not be reduced by the value of support services provided by Altruist. The benefits provided to or on behalf of Tencap are considered compensation to Tencap in connection of providing services to clients, and therefore should be considered in assessing the reasonableness of the compensation arrangement between Tencap and clients. Access to such economic benefits creates and a financial incentive for Tencap to maintain client accounts through Altruist as introducing broker and custodian. Altruist may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Altruist may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Altruist may also provide us with other benefits such as occasional business entertainment of our personnel. Tencap Interest in Schwab’s and Altruist’s Services The availability of additional benefits from Schwab and Altruist benefits Tencap because Tencap does not have to produce or purchase them. Tencap does not have to pay for Schwab’s or Altruist’s services. The fact that Tencap receives these benefits from Schwab and Altruist creates an incentive for Tencap to recommend the use of Schwab and Altruist rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. Tencap believes, however, that taken in the aggregate, Tencap’s recommendation of Schwab and Altruist as custodians and brokers is in the best interests of Tencap clients. Tencap’s selection is primarily supported by the scope, quality, and price of Schwab’s and Tencap’s services (see “How Tencap Selects Brokers/Custodians”) and not by the services that benefit only Tencap. Tencap understands its duty for best execution and considers all factors in making recommendations to clients. These research services may be useful in servicing all clients and may not be used in connection with any particular account that may have paid compensation to the firm providing such services. While Tencap may not always obtain the lowest commission rate, Tencap believes the rate is reasonable in relation to the value of the brokerage and research services provided. We believe that our selection of Schwab and Altruist as broker-dealer/custodian is in the best interests of our clients. Our belief is primarily supported by the scope and quality of services Schwab and Altruist provide to our clients and not services that benefit only us. To address the existence of this conflict, on a periodic basis, we conduct a best execution review considering the full range and quality of Schwab’s and Altruist’ services, including execution quality, the value of research provided, financial strength, and responsiveness to our requests for trade data and other information. Our obligation is not necessarily to get the lowest price but to obtain the best qualitative execution. Aggregating Securities Transactions for Client Accounts Tencap manages each account separately and, therefore, does not aggregate purchases and sales and other transactions. If orders are not aggregated, some clients purchasing securities around the same time may receive a less favorable price than other clients which may cost clients more money. Review of Accounts - Item 13 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Investment Advisor Representative(s) associated with the account. Account reviews are performed more frequently when market conditions dictate. Reviews of Client  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 22 accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial Plans are considered complete when recommendations are delivered to the client and a review is done only upon request of client. Clients are invited to meet with the firm at least annually to discuss their accounts and any changes to their financial situation. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of client’s accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Content of Client Provided Reports and Frequency Clients receive account statements no less than monthly for managed accounts. Account statements are issued by the qualified custodian holding the client’s account. Client receives confirmations of each transaction in their account from the Custodian. Under financial planning services, the client will receive a one-time written financial plan. No ongoing reviews will be provided unless the client engages us for a financial plan update. Client Referrals and Other Compensation - Item 14 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Custodial Benefits As described in Item 12 above, we receive economic benefits from our custodial broker dealers in the form of support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at these custodial broker dealers. The availability of custodial products and services is not dependent upon or based on the specific investment advice we provide our clients, such as buying or selling specific securities or specific types of securities for our clients. Economic Benefits Received from Vendors and Product Sponsors Occasionally, our firm and our Associated Persons will receive additional compensation from vendors. Compensation could include such items as gifts; an occasional dinner or ticket to a sporting event; reimbursement in connection with educational meetings with an Associated Person, reimbursement for consulting services, client workshops, or events; or marketing events or advertising initiatives, including services for identifying prospective clients. Receipt of all additional economic benefits presents a conflict of interest because our firm and Associated Persons have an incentive to recommend and use custodian(s) and vendors based on the additional economic benefits obtained rather than solely on the client’s needs. We address this conflict of interest by recommending custodian(s) and vendors that we, in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation contractually or otherwise, to use any of the vendors recommended by us. Advisory Firm Payments for Client Referrals Tencap does not compensate for client referrals.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 23 Custody - Item 15 Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any reports prepared by the sub-adviser or Tencap. Where we directly debit your account(s) for the payment of our advisory fees, we are deemed to exercise custody over your funds or securities. However, we do not have physical custody of any of your funds and/or securities. Tencap will also be deemed to have custody in cases where a client grants our firm Standing Letters of Authorization (“SLOA”) for third party transfers. In such cases, Tencap and its qualified custodian will meet the following seven (7) conditions in order to avoid maintaining full custody and be subject to the surprise exam requirement: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes Tencap, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. Tencap has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. Tencap maintains records showing that the third party is not a related party nor located at the same address as Tencap. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Investment Discretion - Item 16 Discretionary Authority for Trading Tencap requires discretionary authority to manage securities accounts on behalf of Clients. Tencap has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Client will authorize Tencap discretionary authority as stated within the Investment Advisory Agreement. Tencap allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to Tencap in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. Tencap does not receive any portion of the transaction fees or commissions paid by the Client to the custodian.  Tencap Wealth Coaching Form ADV Part 2A Brochure Page 24 Voting Client Securities - Item 17 Proxy Votes Tencap does not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, Tencap will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Financial Information - Item 18 Balance Sheet A balance sheet is not required to be provided because Tencap does not serve as a custodian for client funds or securities and Tencap does not require prepayment of fees of more than $1,200 per client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Tencap has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Bankruptcy Petitions During the Past Ten Years Tencap has not been the subject of a bankruptcy proceeding. Requirements of State-Registered Advisers - Item 19 This section is not applicable because our firm is SEC-registered.