Overview

Assets Under Management: $868 million
Headquarters: LITTLE ROCK, AR
High-Net-Worth Clients: 63
Average Client Assets: $6.0 million

Frequently Asked Questions

TMB CAPITAL PARTNERS, LLC charges 1.00% on the first $1 million, 0.85% on the next $2 million, 0.75% on the next $4 million, 0.50% on the next $5 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #335750), TMB CAPITAL PARTNERS, LLC is subject to fiduciary duty under federal law.

TMB CAPITAL PARTNERS, LLC is headquartered in LITTLE ROCK, AR.

TMB CAPITAL PARTNERS, LLC serves 63 high-net-worth clients according to their SEC filing dated February 04, 2026. View client details ↓

According to their SEC Form ADV, TMB CAPITAL PARTNERS, LLC offers financial planning, portfolio management for individuals, and pension consulting services. View all service details ↓

TMB CAPITAL PARTNERS, LLC manages $868 million in client assets according to their SEC filing dated February 04, 2026.

According to their SEC Form ADV, TMB CAPITAL PARTNERS, LLC serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

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

Fee Structure

Primary Fee Schedule (TMB CAPITAL PARTNERS, LLC DISCLOSURE BROCHURE)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $2,000,000 0.85%
$2,000,001 $3,500,000 0.75%
$3,500,001 $5,000,000 0.50%
$5,000,001 $10,000,000 0.40%
$10,000,001 and above Negotiable
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $37,250 0.74%
$10 million $57,250 0.57%
$50 million Negotiable Negotiable
$100 million Negotiable Negotiable

Clients

Number of High-Net-Worth Clients: 63
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 43.26%
Average Client Assets: $6.0 million
Total Client Accounts: 456
Discretionary Accounts: 456
Minimum Account Size: None

Regulatory Filings

CRD Number: 335750
Filing ID: 2044949
Last Filing Date: 2026-02-04 13:30:16

Form ADV Documents

Primary Brochure: TMB CAPITAL PARTNERS, LLC DISCLOSURE BROCHURE (2026-02-04)

View Document Text
TMB Capital Partners, LLC Form ADV Part 2A – Disclosure Brochure Effective: February 4, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 501-671-1140. TMB 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 TMB Capital to assist you in determining whether to retain the Advisor. Additional information about TMB 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# 335750. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.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 TMB Capital. For convenience, the Advisor has combined these documents into a single disclosure document. TMB 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. TMB Capital encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since its last filing and distribution to clients: • The Advisor has established an institutional relationship with Fidelity. Please see Item 12 and 14 for additional information. • The Advisor offers a wrap fee program. Please see Item 4 and Appendix 1 for more information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335750. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 501-671-1140. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 2 Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 3 Item 3 – Table of Contents .................................................................................................................................... 4 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 6 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 .................................................................................................................. 8 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 .......................................................... 9 A. Methods of Analysis ....................................................................................................................................................... 9 B. Risk of Loss .................................................................................................................................................................... 9 Item 9 – Disciplinary Information ....................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11 A. Code of Ethics .............................................................................................................................................................. 11 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 ............................................................................................................................ 12 A. Recommendation of Custodian[s] ................................................................................................................................ 12 B. Aggregating and Allocating Trades .............................................................................................................................. 12 Item 13 – Review of Accounts ............................................................................................................................ 13 A. Frequency of Reviews .................................................................................................................................................. 13 B. Causes for Reviews ..................................................................................................................................................... 13 C. Review Reports ............................................................................................................................................................ 13 Item 14 – Client Referrals and Other Compensation ........................................................................................ 13 A. Compensation Received by TMB Capital ..................................................................................................................... 13 B. Compensation for Client Referrals ............................................................................................................................... 14 Item 15 – Custody ................................................................................................................................................ 14 Item 16 – Investment Discretion ......................................................................................................................... 14 Item 17 – Voting Client Securities ...................................................................................................................... 14 Item 18 – Financial Information .......................................................................................................................... 14 Appendix 1 - Wrap Fee Program………………………………………………………………………………………...15 Privacy Policy ...................................................................................................................................................... 34 TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 3 Item 4 – Advisory Services A. Firm Information TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Arkansas. TMB Capital was founded in February 2025. The Advisor is owned by TMB Capital Partners Holding Company LLC, and operated by Scott E. Tabor (Principal and Chief Compliance Officer), William M. McMillan, AIF® (Principal), and Benjamin A. Bailey (Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by TMB Capital. B. Advisory Services Offered TMB Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, banks, corporations, charities, 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. TMB Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services TMB Capital provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services and a broad range of comprehensive financial planning. Investment Management Services – The Advisor provides discretionary investment management services. TMB 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. TMB Capital will then construct an investment portfolio mostly utilizing model portfolios to meet the Client’s investment goals. These model portfolios are primarily made up of exchange-traded funds (“ETFs”), mutual funds, and individual stocks. The Advisor may also utilize individual bonds, options contracts, and/or alternative investments 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. TMB 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. TMB 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. TMB Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. TMB Capital may recommend, on occasion, redistributing investment allocations to diversify the portfolio. TMB 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. TMB Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 4 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services – The Advisor provides a variety of financial planning and consulting services to Clients as part of its wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. TMB 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 The Advisor provides 3(21) and 3(38) 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 generally include: Investment Policy Statement (“IPS”) Design and Monitoring • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • Ongoing Investment Recommendation and Assistance • Performance Reports • ERISA 404(c) Assistance • Benchmarking Services These services are provided by the Advisor 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 the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 5 Donor Advised Fund Services – The Advisor also provides the Raymond James Charitable Donor Advised Fund (“DAF”) and the Arkansas Community Foundation Donor Advised Fund (“DAF”) to Clients via Raymond James Charitable and Arkansas Community Foundation, both are a web-based interface and administrative solution for charitable giving to philanthropic vehicles via the Raymond James Charitable Fund (“RJCF”) and the Arkansas Community Foundation (“ACF”), both are IRS approved philanthropic vehicle established for the purpose of managing charitable donations contributed by or on behalf of donor clients. The DAF allows the Advisor to actively manage assets that have been donated to and are owned by RJCF or ACF, while charging an investment management fee. The Advisor’s DAF participation is in conjunction with approval by the RJCF or ACF Investment Committee for the Advisor to operate as an advisory manager on the platform. Both the Raymond James Charitable Fund and Arkansas Community Foundation Charitable Fund are independent companies and unaffiliated with the Advisor. C. Client Account Management Prior to engaging TMB Capital to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – TMB Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – TMB 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 – TMB 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 – TMB Capital will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs TMB Capital includes, securities transaction fees (herein “Covered Costs”) together with its wealth management fees for Client accounts held at Fidelity. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its wealth management services for its Clients. The Advisor sponsors the TMB Capital Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2025, TMB Capital manages $867,846,603 in client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior calendar quarter. Wealth management fees are based on the following blended tiered schedule: TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 6 Assets Under Management ($) Annual Rate (%) First $1,000,000 Next $1,000,000 Next $1,500,000 Next $1,500,000 Next $5,000,000 Above $10,000,000 1.00% 0.85% 0.75% 0.50% 0.40% Negotiable Certain legacy client relationships may be charged a higher wealth management fee than described in the blended tiered schedule above. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by TMB 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. Retirement Plan Advisory Services Retirement plan advisory fees are charged an annual asset-based fee of up to 1.00%. Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with TMB 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 wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting wealth management fees to be deducted by TMB Capital to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. 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 in connection with investments made on behalf of the Client’s accounts. TMB Capital includes Covered Costs as part of its overall wealth management fee for account[s] held at Fidelity through the TMB Capital Wrap Fee Program. Securities transaction fees for Client- directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. Clients may incur certain fees or charges imposed by third parties, other than TMB Capital, in connection with investments made on behalf of the Client’s account[s]. For accounts at Raymond James the Client is responsible for all custody and securities execution fees charged by Raymond James, 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 TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 7 the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. For accounts at Raymond James, the fees charged by TMB Capital are separate and distinct from these custody and execution fees. In addition, all fees paid to TMB Capital wealth management 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 TMB Capital, but would not receive the services provided by TMB 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 TMB Capital to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services TMB Capital may be compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the Billing Period. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities TMB 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. Insurance Agency Affiliation Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are separate and in addition to wealth management fees. This practice presents a conflict of interest as an Advisory Person who is also an insurance professional will have an incentive to recommend insurance products to the Client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractual or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management TMB Capital does not charge performance-based fees for its investment advisory services. The fees charged by TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 8 TMB 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 TMB Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, banks, corporations, charities, and retirement plans. TMB Capital generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis TMB Capital employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from TMB 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, TMB Capital generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. TMB 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, TMB 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. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 9 Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers, and self- liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 10 Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving TMB Capital or its management persons. TMB 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# 335750. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliation As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset wealth management fees. This presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by the Advisor or Advisory Persons. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics TMB 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 TMB Capital (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. TMB Capital and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of TMB 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 501-671-1140. B. Personal Trading with Material Interest TMB Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. TMB 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. TMB Capital does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients TMB 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 TMB Capital requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While TMB 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 TMB Capital, or any Supervised Person of TMB Capital, transact in any security to the detriment of any Client. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 11 Item 12 – Brokerage Practices A. Recommendation of Custodian[s] TMB 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 TMB Capital to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, TMB Capital does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where TMB 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 TMB Capital. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. TMB Capital may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc., member New York Stock Exchange/SPIC (“Raymond James”) or Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC, (collectively “Fidelity”). Raymond James and Fidelity are FINRA-registered broker-dealers and New York Stock Exchange/SIPC members. Raymond James or Fidelity will serve as the Client’s “qualified custodian”. The Advisor maintains institutional relationships with Raymond James and Fidelity, whereby the Advisor receives economic benefits from the Custodian. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. TMB Capital does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - TMB 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 TMB 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]). TMB 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. TMB Capital will execute its transactions through the Custodian as authorized by the Client. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 12 Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Scott E. Tabor, Chief Compliance Officer of TMB 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 TMB 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 TMB Capital TMB Capital is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. TMB Capital does not receive commissions or other compensation from product sponsors, broker-dealers or any un- related third party. TMB 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, TMB Capital may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform – Raymond James As noted in item 12, the Advisor has established an institutional relationship with Raymond James to assist the Advisor in managing Client account[s]. As part of the arrangement, Raymond James makes available to the Advisor, certain research and brokerage services, including research services obtained by Raymond James directly from independent research companies. The Advisor may also receive additional services and support from Raymond James. The Advisor has an incentive to continue to use or expand the use of Raymond James's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support because the Advisor renders wealth management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Participation in Institutional Advisor Platform – Fidelity Alos, as noted in item 12, the Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 13 services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody TMB Capital is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct TMB Capital to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion TMB 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 TMB 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 a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by TMB Capital will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities TMB Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither TMB Capital, nor its management, have any adverse financial situations that would reasonably impair the ability of TMB Capital to meet all obligations to its Clients. Neither TMB Capital, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 14 TMB Capital Partners, LLC Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) Effective: February 4, 2026 This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the TMB Capital Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete TMB Capital Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the TMB Capital Disclosure Brochure, please contact the Advisor at 501-671-1140. TMB Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”) The information in this Wrap Fee Program 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 Wrap Fee Program Brochure provides information about TMB Capital to assist you in determining whether to retain the Advisor. Additional information about TMB Capital and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 335750. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 15 Item 2 – Material Changes Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since its last filing and distribution to clients: • The Advisor has established an institutional relationship with Fidelity. Please see Item 12 and 14 for additional information. • The Advisor offers a wrap fee program. Please see Item 4 and Appendix 1 for more information. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete TMB Capital Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of TMB Capital. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 335750. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at 501-671-1140. Item 3 – Table of Contents Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Services Fees and Compensation ....................................................................................................... 17 Item 5 – Account Requirements and Types of Clients ....................................................................................... 4 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................................ 4 Item 7 – Client Information Provided to Portfolio Managers ............................................................................. 4 Item 8 – Client Contact with Portfolio Managers ................................................................................................ 6 Item 9 – Additional Information ............................................................................................................................ 6 Item 10 – Requirements for State-Registered Advisors ..................................................................................... 6 TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 16 Item 4 – Services Fees and Compensation A. Services TMB Capital provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the TMB Capital Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting TMB Capital as your investment advisor. As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, TMB Capital includes, in addition to securities transaction fees (herein “Covered Costs”) as part of the overall wealth management fee for accounts held at Fidelity. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The Advisor’s recommended Custodians do not charge securities transaction fees for exchange-traded fund (“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and other types of investments. The Advisor sponsors the TMB Capital Wrap Fee Program. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of Covered Costs into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references back to the TMB Capital Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on TMB Capital’s investment philosophy and related services. B. Program Costs Advisory services provided by TMB Capital are offered in a wrap fee structure whereby Covered Costs are included in the overall wealth management fee paid to TMB Capital for accounts held at Fidelity. As the level of activity in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. As noted above, the Advisor’s recommended Custodians do not charge securities transaction fees for ETF and equity trades in Client accounts, but typically charges for mutual funds and other types of investments. As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Wealth Management Services Wealth management fees are paid in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior calendar quarter. Wealth management fees are based on the following blended tiered schedule: Assets Under Management ($) Annual Rate (%) First $1,000,000 Next $1,000,000 Next $1,500,000 Next $1,500,000 Next $5,000,000 Above $10,000,000 1.00% 0.85% 0.75% 0.50% 0.40% Negotiable Certain legacy client relationships may be charged a higher wealth management fee than described in the blended tiered schedule above. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 17 fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by TMB 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. Retirement Plan Advisory Services Retirement plan advisory fees are charged an annual asset-based fee of up to 1.00%. Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary investment management services provided by TMB Capital, as part of its overall investment advisory fee. In addition, all fees paid to TMB Capital for investment advisory services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds 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. Securities transaction fees for Client- directed trades will be charged back to the Client. In connection with the discretionary investment management services provided by TMB Capital, the Client will incur other costs assessed by the Custodian or other third parties, other than the Covered Costs noted above, such securities transaction fees. The Advisor does not control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by TMB Capital to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation TMB Capital is the sponsor and portfolio manager of this Wrap Fee Program. TMB Capital receives wealth management fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the Client’s account[s]. Item 5 – Account Requirements and Types of Clients TMB Capital offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses, banks, corporations, charities, and retirement plans. TMB Capital generally does not impose a minimum account size for establishing a relationship. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection TMB Capital serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons TMB Capital personnel serve as portfolio managers for this Wrap Fee Program. Performance-Based Fees TMB Capital does not charge performance-based fees for its investment advisory services. The fees charged by TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 18 Supervised Persons TMB Capital Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. 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. TMB 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. Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 19 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. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers, and self- liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). 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. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting TMB Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 7 – Client Information Provided to Portfolio Managers TMB Capital is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the TMB Capital Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers TMB Capital is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at TMB Capital. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations There are no legal, regulatory or disciplinary events involving TMB Capital or its management persons. TMB 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# 335750. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 20 Please see Item 9 of the TMB Capital Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information TMB Capital has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to TMB Capital’s compliance program (our “Supervised Persons”). Complete details on the TMB Capital Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Investments in Review of Accounts Client accounts are monitored on a regular and continuous basis by Advisory Persons of TMB Capital under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Other Compensation Participation in Institutional Advisor Platform – Raymond James As noted in item 12, the Advisor has established an institutional relationship with Raymond James to assist the Advisor in managing Client account[s]. As part of the arrangement, Raymond James makes available to the Advisor, certain research and brokerage services, including research services obtained by Raymond James directly from independent research companies. The Advisor may also receive additional services and support from Raymond James. The Advisor has an incentive to continue to use or expand the use of Raymond James's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support because the Advisor renders wealth management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Participation in Institutional Advisor Platform – Fidelity Alos, as noted in item 12, the Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 21 provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. Please se Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on additional compensation that may be received by TMB Capital or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside business activities and the associated compensation. Client Referrals from Solicitors The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Financial Information Neither TMB Capital, nor its management, have any adverse financial situations that would reasonably impair the ability of TMB Capital to meet all obligations to its Clients. Neither TMB Capital, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 22 Form ADV Part 2B – Brochure Supplement for Scott E. Tabor Principal and Chief Compliance Officer Effective: February 4, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Scott E. Tabor (CRD# 2233071) in addition to the information contained in the TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure Supplement, please contact us at 501-671-1140. Additional information about Mr. Tabor 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# 2233071. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 23 Item 2 – Educational Background and Business Experience Scott E. Tabor, born in 1968, is dedicated to advising Clients of TMB Capital as a Principal and the Chief Compliance Officer. Mr. Tabor earned his BSBA in Finance/Insurance from the University of Arkansas, Fayetteville in 1991. Additional information regarding Mr. Tabor’s employment history is included below. Employment History: Principal and Chief Compliance Officer, TMB Capital Partners, LLC Financial Advisor, Raymond James & Associates, Inc. 07/2025 to Present 02/2013 to 07/2025 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Tabor. Mr. Tabor 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. Tabor. 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. Tabor. However, we do encourage you to independently view the background of Mr. Tabor on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2233071. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Tabor is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Tabor’s role with TMB Capital. As an insurance professional, Mr. Tabor will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Tabor is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Tabor or the Advisor. Mr. Tabor spends approximately 10% of his time per month in this capacity. Central Acquisitions Mr. Tabor also serves as a Co-owner of Central Acquisitions, a termite and pest control business. Mr. Tabor is compensated for this activity and spends less than 5% of his time per month in this capacity. Cottondale Lane River LLC Mr. Tabor also serves as a Partner of Cottondale Lane River LLC, an LLC for a building lease. Mr. Tabor is not compensated for this activity and spends less than 5% of his time per month in this capacity. CR Resource Group Mr. Tabor also serves as a Co-owner of CR Resource Group, a natural resource recycling company. Mr. Tabor is not compensated for this activity and spends less than 5% of his time per month in this capacity. AR Game and Fish Foundation Mr. Tabor is also a Board Member for the AR Game and Fish Foundation, a state natural resource entity. Mr. Tabor is not compensated for this activity, and spends less than 5% of his time per month in this capacity. SDT Rev Trust Mr. Tabor also serves as a Trustee for the SDT Rev Trust, a family trust. Mr. Tabor is compensated for this activity, and spends approximately 5% of his time per month in this capacity. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 24 Item 5 – Additional Compensation Mr. Tabor has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Tabor serves as a Principal and the Chief Compliance Officer of TMB Capital. Mr. Tabor can be reached at 501- 671-1140. TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 25 Form ADV Part 2B – Brochure Supplement for William M. McMillan, AIF® Principal Effective: February 4, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of William M. McMillan, AIF® (CRD# 4268503) in addition to the information contained in the TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure Supplement, please contact us at 501-671-1140. Additional information about Mr. McMillan 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# 4268503. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 26 Item 2 – Educational Background and Business Experience William M. McMillan, AIF®, born in 1975, is dedicated to advising Clients of TMB Capital as a Principal. Mr. McMillan earned his Master of Business Administration from University of Memphis in 2000. Mr. McMillan also earned his Bachelor of Business Administration in Finance from University of Arkansas in 1998. Additional information regarding Mr. McMillan’s employment history is included below. Employment History: Principal, TMB Capital Partners, LLC Registered Associate, Raymond James & Associates, Inc. 07/2025 to Present 02/2013 to 07/2025 Accredited Investment Fiduciary™ (“AIF®”) The AIF® mark is held by the Center for Fiduciary Studies, LLC, a Fiduciary360 (fi360) company. The professional designations awarded by fi360 demonstrate the focus on all the components of a comprehensive investment process, related fiduciary standards of care, and commitment to excellence. AIF® designees undergo an initial training program, annual continuing education, and pledge to abide by the designation's code of ethics. investment Since October 2002, the Accredited Investment Fiduciary™ (AIF®) designation has been the mark of commitment to a standard of fiduciary investment excellence. Those who earn the AIF® mark successfully complete a specialized program on fiduciary standards of care and subsequently passed a comprehensive examination. AIF® designees demonstrate a thorough understanding of fi360's Prudent Practices for investment advisors and stewards. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. McMillan. Mr. McMillan 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. McMillan. 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. McMillan. However, we do encourage you to independently view the background of Mr. McMillan on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4268503. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. McMillan is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. McMillan’s role with TMB Capital. As an insurance professional, Mr. McMillan will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. McMillan is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. McMillan or the Advisor. Mr. McMillan spends approximately 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. McMillan has an additional business activity where compensation is received that is detailed in Item 4 above. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 27 Item 6 – Supervision Mr. McMillan serves as a Principal of TMB Capital and is supervised by Scott Tabor, the Chief Compliance Officer. Mr. Tabor can be reached at 501-671-1140. TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 28 Form ADV Part 2B – Brochure Supplement for Benjamin A. Bailey Principal Effective: February 4, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Benjamin A. Bailey (CRD# 5171116) in addition to the information contained in the TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure Supplement, please contact us at 501-671-1140. Additional information about Mr. Bailey 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# 5171116. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 29 Item 2 – Educational Background and Business Experience Benjamin A. Bailey, born in 1984, is dedicated to advising Clients of TMB Capital as a Principal. Mr. Bailey earned a BSBA in Finance with an emphasis on Financial Management of Investments from University of Arkansas in 2006. Additional information regarding Mr. Bailey’s employment history is included below. Employment History: Principal, TMB Capital Partners, LLC First Vice President, Financial Advisor, Raymond James & Associates, Inc. 07/2025 to Present 02/2013 to 07/2025 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Bailey. Mr. Bailey 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. Bailey. 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. Bailey. However, we do encourage you to independently view the background of Mr. Bailey on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5171116. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Bailey is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Bailey’s role with TMB Capital. As an insurance professional, Mr. Bailey will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Bailey is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Bailey or the Advisor. Mr. Bailey spends approximately 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Bailey has an additional business activity where compensation is received that is detailed in Item 4 above. Item 6 – Supervision Mr. Bailey serves as a Principal of TMB Capital and is supervised by Scott Tabor, the Chief Compliance Officer. Mr. Tabor can be reached at 501-671-1140. TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced. TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 30 Form ADV Part 2B – Brochure Supplement for Zachary G. Sokora Vice President Effective: February 4, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Zachary G. Sokora (CRD# 7162495) in addition to the information contained in the TMB Capital Partners, LLC (“TMB Capital” or the “Advisor”, CRD# 335750) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the TMB Capital Disclosure Brochure or this Brochure Supplement, please contact us at 501-671-1140. Additional information about Mr. Sokora 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# 7162495. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 31 Item 2 – Educational Background and Business Experience Zachary G. Sokora, born in 1996, is dedicated to advising Clients of TMB Capital as a Vice President. Mr. Sokora earned his Bachelor’s Degree in Finance from the University of Arkansas in 2019. Additional information regarding Mr. Sokora’s employment history is included below. Employment History: Vice President, TMB Capital Partners, LLC Financial Advisor, Raymond James & Associates, Inc. Institutional Equity Sales, Stephens Inc. Investment Sales Officer I, BOK Financial Securities, Inc. 07/2025 to Present 05/2024 to 07/2025 09/2022 to 05/2024 08/2019 to 09/2022 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Sokora. Mr. Sokora 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. Sokora. 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. Sokora. However, we do encourage you to independently view the background of Mr. Sokora on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7162495. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Sokora is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Sokora’s role with TMB Capital. As an insurance professional, Mr. Sokora will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Sokora is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Sokora or the Advisor. Mr. Sokora spends approximately 10% of his time per month in this capacity. The Big Short LLC Mr. Sokora also serves as a Partner of The Big Short LLC, which owns a rental property in Arkansas. Mr. Sokora is compensated and spends less than 5% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Sokora has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Sokora serves as a Vice President of TMB Capital and is supervised by Scott Tabor, the Chief Compliance Officer. Mr. Tabor can be reached at 501-671-1140. TMB Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of TMB Capital. Further, TMB Capital is subject to regulatory oversight by various agencies. These agencies require registration by TMB Capital and its Supervised Persons. As a registered entity, TMB Capital is subject to examinations by regulators, which may be announced or unannounced. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 32 TMB 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. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 33 Privacy Policy Effective: February 4, 2026 Our Commitment to You TMB Capital Partners, LLC (“TMB 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. TMB 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. TMB Capital does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 34 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 to: processing No Not Shared Yes Yes Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes TMB 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 TMB Capital or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients TMB 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. SMS Messaging The Advisor’s SMS messaging provides the Client with timely and relevant communications directly from the Advisor. Clients 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. SMS opt-in or phone numbers for the purpose of SMS are not shared with any third parties or affiliate companies for marketing purposes. The Advisor will never share, sell, or trade your personal information, including phone numbers and SMS consent, with any third parties under any circumstances. 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 501-671-1140. TMB Capital Partners, LLC 2226 Cottondale Lane, STE 110, Little Rock, AR 72202 Phone: 501-671-1140 http://www.tmbcapitalpartners.com Page 35