Triad Investment Management, LLC

ITEM 1 – COVER PAGE 1301 Dove Street Suite 1080 Newport Beach, CA 92660 (949) 679-3991 www.triadim.com (CRD # 146786) Form ADV, Part 2A Brochure June 16, 2026 This brochure provides information about the qualifications and business practices of Triad Investment Management, LLC. If you have any questions about the contents of this brochure, please contact David Hutchison at (949) 679-3991 or dhutchison@triadim.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Any reference to or use of the terms “registered investment adviser” or “registered,” does not imply that Triad Investment Management, LLC, or any person associated with Triad Investment Management, LLC has achieved a certain level of skill or training. Additional information about Triad Investment Management, LLC is available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 2 – MATERIAL CHANGES The purpose of this page is to inform you of any material changes to our brochure. If you are receiving this brochure for the first time this section may not be relevant to you. Triad Investment Management, LLC (“Triad”) reviews and updates our brochure at least annually to make sure that it is still current. We have not made any material changes since the previous annual update to our brochure, dated February 23, 2026. 2 Triad Investment Management Part 2A Brochure  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE ........................................................................................................................1 ITEM 2 – MATERIAL CHANGES ............................................................................................................2 ITEM 3 – TABLE OF CONTENTS ............................................................................................................3 ITEM 4 – ADVISORY BUSINESS ............................................................................................................5 Description of Advisory Firm .................................................................................................................... 5 Advisory Services Offered ......................................................................................................................... 6 Wrap Fee Programs .................................................................................................................................. 8 Assets Under Management ...................................................................................................................... 8 ITEM 5 – FEES AND COMPENSATION ...................................................................................................8 Fee Schedule ............................................................................................................................................. 8 Billing Method .......................................................................................................................................... 9 Other Fees and Expenses .......................................................................................................................... 9 Termination ............................................................................................................................................ 10 Other Compensation .............................................................................................................................. 10 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................................... 10 ITEM 7 – TYPES OF CLIENTS .............................................................................................................. 10 Account Requirements ........................................................................................................................... 10 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................ 11 Methods of Analysis ............................................................................................................................... 11 Investment Strategies ............................................................................................................................. 11 General Risk of Loss Statement .............................................................................................................. 12 Risks ........................................................................................................................................................ 12 Other Risks .............................................................................................................................................. 16 ITEM 9 – DISCIPLINARY INFORMATION ............................................................................................. 16 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................. 16 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ......................................................................................................................................... 17 Code of Ethics ......................................................................................................................................... 17 ITEM 12 – BROKERAGE PRACTICES .................................................................................................... 18 Factors Considered in Selecting Broker-Dealers for Client Transactions ............................................... 18 ITEM 13 – REVIEW OF ACCOUNTS ..................................................................................................... 21 Managed Account Reviews .................................................................................................................... 21 3 Triad Investment Management Part 2A Brochure  Account Reporting .................................................................................................................................. 22 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .............................................................. 22 Client Referral Fees ................................................................................................................................. 22 Outside Referrals .................................................................................................................................... 22 ITEM 15 – CUSTODY ......................................................................................................................... 23 ITEM 16 – INVESTMENT DISCRETION ................................................................................................ 23 ITEM 17 – VOTING CLIENT SECURITIES .............................................................................................. 24 ITEM 18 – FINANCIAL INFORMATION ................................................................................................ 25 Form ADV, Part 2B Brochure Supplement ........................................................................................... i John Heldman, CFA® ........................................................................................................................... i David Hutchison, CFA® ........................................................................................................................ i ITEM 1 - COVER PAGE ................................................................................................................................ i John Heldman .................................................................................................................................... ii ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ...................................................... ii ITEM 3 - DISCIPLINARY INFORMATION ..................................................................................................... ii ITEM 4 - OTHER BUSINESS ACTIVITIES ...................................................................................................... ii ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... ii ITEM 6 - SUPERVISION .............................................................................................................................. ii David Hutchison ................................................................................................................................ iii ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... iii ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iii ITEM 4 - OTHER BUSINESS ACTIVITIES ..................................................................................................... iii ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iii ITEM 6 - SUPERVISION ............................................................................................................................. iv Client Privacy Notice ......................................................................................................................... A 4 Triad Investment Management Part 2A Brochure  ITEM 4 – ADVISORY BUSINESS Description of Advisory Firm Triad Investment Management, LLC (“Triad,” “we,” “our,” or “us”) is a privately owned limited liability company headquartered in Newport Beach, CA. John Heldman, Partner, founded Triad in 2008. The Heldman Family Trust and Hutchison Family Trust are the principal owners of the firm. Fiduciary Duty Registered investment advisers are considered fiduciaries under state and federal law. Our fiduciary duty carries with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty. Duty of Care The duty of care includes, among other things: 1. the duty to provide advice that is in the best interest of the client; 2. the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades; and 3. the duty to provide advice and monitoring over the course of the relationship. The duty to provide advice suitable to each client based on a reasonable understanding of the client’s objectives is a critical component of the duty of care. Providing suitable advice includes making a reasonable inquiry into the client’s financial situation, investment experience, and financial goals and then updating this information as necessary throughout the course of the relationship to reflect the client’s changing objectives over time and adjusting the advice we provide to reflect any changed circumstances. When Triad has the responsibility to select broker-dealers to execute client trades in discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s services and so the determinative factor is not necessarily the lowest possible commission cost but whether the transaction represents the best qualitative execution. Moreover, we periodically and systematically evaluate the execution we receive on behalf of our clients. Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the best interest of the client, taking into account the scope of the agreed relationship. This scope is indicated by the duration and nature of the services as outlined in each client’s advisory arrangement and extends to all personalized advice provided to clients. Duty of Loyalty Triad adheres to a duty of loyalty where we seek to serve the best interests of our clients and never subordinate the interests of our clients to our own. Simply put, Triad cannot place its own interests ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest which might incline Triad, consciously or unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to be 5 Triad Investment Management Part 2A Brochure  full and fair, it should be sufficiently specific so that each client is able to understand the material fact or conflict of interest and make an informed decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they can use the information within to decide whether or not to enter into an advisory relationship. Advisory Services Offered Triad offers the following services to advisory clients: Investment Management Services Triad provides continuous and regular investment supervisory services on a discretionary basis. John Heldman and Dave Hutchison work with clients and have the ongoing responsibility to select and/or make recommendations, based upon the objectives of the client, as to specific securities or other investments that Triad purchases or sells in client accounts. Triad’s recommendations for new investments will primarily include: 1. Equity securities 2. Exchange-traded funds (ETFs) 3. Closed-end mutual funds 4. Real estate investment trusts (REIT) 5. Money market funds and other cash equivalents Additionally, Triad’s recommendations, depending on the individual investment objectives and needs of the client may include: 1. Foreign securities listed on US exchanges (ADRs) 2. Fixed income securities 3. Business development companies (BDCs) Triad also occasionally offers advice regarding additional types of investments if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. Triad may offer investment advice on any investment held by the client at the start of the advisory relationship. We describe the material investment risks for many of the securities that we recommend in Item 8 below. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the Fees charged for investment management services below under Item 5 - Fees and Compensation. Our Fiduciary Duties to Clients with Retirement Plans When we provide investment advice to you regarding any retirement plan or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 6 Triad Investment Management Part 2A Brochure  Under this special rule’s provisions, we must: 1. Meet a professional standard of care when making investment recommendations (give prudent advice); 2. Never put our financial interests ahead of yours when making recommendations (give loyal advice); 3. Avoid misleading statements about conflicts of interest, fees, and investments; 4. Follow policies and procedures designed to ensure that we give advice that is in your best interest; 5. Charge no more than is reasonable for our services; and 6. Give you basic information about conflicts of interest. Participant Account Management Triad utilizes a third-party platform to facilitate discretionary management of the accounts of retirement plan participants, including but not limited to 401(k) and defined contribution plan participant accounts (collectively, “held-away accounts”). These held-away accounts are not maintained with the custodian(s) we recommend but rather custodied at an institution selected by the client and/or their employer. We are not affiliated with the platform in any way and receive no compensation from them for using their platform; however, Triad pays a fee to the third-party platform provider for use of the service. A link will be provided to the client allowing them to connect the held-away account(s) to the platform. Once accounts are connected to the platform, Triad will regularly review the available investment options in these accounts, monitor them, and rebalance them, though using different tools, as necessary. Financial Planning Services Triad does not generally provide comprehensive financial planning services, but we may offer financial planning related services as part of our overall advisory services. These services generally involve providing advice to clients regarding the investment/management of financial resources based upon an analysis of their individual needs. A written plan is generally provided. However, we do not include preparation of any income tax, gift, or estate tax returns, or preparation of any legal documents. Triad does not receive separate compensation for financial planning related services. Limitations on Investments Limitation by Client Triad may limit advice based on certain client-imposed restrictions. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Tailored Services and Client Imposed Restrictions Triad manages client accounts based on the investment strategy, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Triad applies the strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. 7 Triad Investment Management Part 2A Brochure  Our recommendations may be limited if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep Triad informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want Triad to buy or sell certain specific securities or security types in the account. Triad reserves the right not to accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Wrap Fee Programs Triad does not manage accounts as part of a wrap or bundled fee program. Assets Under Management Triad manages client assets in discretionary accounts on a continuous and regular basis. As of December 31, 2025, the total amount of assets under our management was $119,542,078. We did not manage any accounts on a non-discretionary basis. ITEM 5 – FEES AND COMPENSATION Fee Schedule Investment Management Services Triad charges advisory fees for investment management services. Triad‘s advisory fees are charged based on a percentage of the fair market value of the portfolio, per the following schedule: Assets Under Management Initial $2,500,000 Next $2,500,000 Over $5,000,000 Annual Fee 1.50% 1.30% 1.10% Some accounts are under different fee schedules honoring prior agreements. Our standard fee schedules may be negotiable based on a number of factors, which include but are not limited to “grandfathered” accounts, related accounts, and other structures that we may consider in special situations. We also waive advisory fees for Triad employee and related accounts. Participant Account Management Triad’s management fees for held-away accounts (see description in Item 4 – Advisory Business, above) will be charged to the client either by (1) debiting another client brokerage account also managed by Triad; or (2) direct invoice. Triad is not affiliated with the third-party platform in any way and receives no compensation from them for using their platform; however, Triad pays a fee to the third-party platform provider for use of the service. Clients do not pay an additional fee for use of this service. 8 Triad Investment Management Part 2A Brochure  Billing Method Investment Management Services Triad’s advisory fees are payable quarterly in advance at the beginning of each calendar quarter. The formula used for the calculation is as follows: (Annual Rate) x (Total Portfolio Value at Quarter-End) x (# of Days in Advance Quarter / # Days in Current Year). For new client accounts, the first payment is a pro- rata calculation due upon execution of the advisory agreement. The calculation will take into consideration the number of days remaining in the quarter and the initial value of the portfolio. The formula used to calculate the initial advisory fee is as follows: (Annual Rate) x (Initial Portfolio Value) x (Number of Days in Current Quarter/Days in Current Year). Triad aggregates client accounts that have family relationships with each other for purposes of calculating the advisory fees applicable to each client. We generally waive fees for our personnel and their family members. With client authorization, Triad will automatically withdraw Triad’s advisory fee from the client’s account held by an independent custodian. Typically, the custodian withdraws advisory fees from the client’s account during the first month of each quarter based on Triad’s instruction. All clients will receive brokerage statements from the custodian no less frequently than quarterly. The custodian statement will show the deduction of the advisory fee. Triad will send a statement to each client who authorizes us to instruct the custodian to withdraw fees directly from the account. The statement will show the amount of the fee, the value of the client’s assets upon which we based the fee, and the rate used to calculate the fee. It is the client’s responsibility to verify the accuracy of the fee calculation. The custodian will not determine whether the fee is properly calculated. Triad generally purchases securities with readily available market prices for its clients and typically uses the securities prices provided by the client’s custodian to value client account securities. Triad’s Chief Compliance Officer (CCO) periodically spot checks the custodian prices against another pricing source. Triad considers the risk of mispricing of securities to be higher for some securities over others. For example, the fixed income securities that do not trade on a daily basis are at greater risk of being stale than highly liquid equity securities that trade daily. Consequently, greater focus will be placed on the review of securities Triad perceives at greater risk of mispricing. In the event a security is not priced by the client’s custodian or the CCO believes that the custodian’s price does not adequately represent investment value, Triad will price the security using what we believe to be the best information available to us at that time. Other Fees and Expenses Triad’s fees do not include custodian fees. Clients pay all brokerage commissions, stock transfer fees, and/or other similar charges incurred in connection with transactions in accounts from the assets in the account, which are in addition to the fees clients pay to Triad. See Item 12 – Brokerage Practices below for more information. 9 Triad Investment Management Part 2A Brochure  In addition, any fund shares held in a client’s account are subject to fund-related expenses and, if applicable, 12b-1 fees and/or early redemption fees on mutual funds. Each fund’s prospectus fully describes the fees and expenses. All fees paid to Triad for investment advisory services are separate and distinct from the fees and expenses charged by funds. Funds pay advisory fees to their managers, which are indirectly charged to all holders of the fund shares. Termination Investment Management Services Either party may terminate the advisory agreement at any time by providing written notice to the other party. Triad will refund any prepaid, unearned advisory fees based on the effective date of termination. Upon termination of the agreement, we will send the client a prorated refund of unearned advisory fees using the following formula: (Fees Paid) x (Days Remaining in Quarter)/(Total Number of Days in Quarter). In the event the client terminates the investment advisory agreement, Triad will not liquidate any securities in the account unless authorized in writing by the client to do so. In the event of client’s death or disability, Triad will continue management of the account until we are notified of client’s death or disability and given alternative instructions by an authorized party. Other Compensation Triad does not accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Triad does not charge performance-based fees or other fees based on a share of capital gains or capital appreciation of the assets of a client. ITEM 7 – TYPES OF CLIENTS Triad offers discretionary investment advisory services to individuals, including high net worth individuals. In addition, we provide advisory services to foundations and businesses. Account Requirements Generally, Triad requires clients to maintain a minimum relationship of $1,000,000. Significant funds withdrawal may result in a request for additional fund deposits to continue with management of accounts. We generally combine family accounts to meet the account size minimum. Triad may reduce or waive the account minimum requirements at our discretion. 10 Triad Investment Management Part 2A Brochure  ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis Methods of Analysis for Selecting Securities Triad uses fundamental analysis in the selection of individual securities. Additionally, Triad may use specific strategies or resources in the method of analysis and selection of fixed income securities. Fundamental Analysis Fundamental analysis typically involves analysis of corporate financial statements, management presentations, specialized research publications, and general news sources. Specifically, Triad’s analysis is focused on three primary aspects of each corporation: the degree of competitive advantages relative to competitors, management abilities, and shareholder-aligned incentives, and the perceived absolute and relative attractiveness of a security’s valuation. Debt Securities (Fixed Income) Triad considers the financial strength of the debt issuer, call provisions, liquidity factors, and bond insurance in selecting bonds for purchase. Triad reviews prospectuses and other publicly available information, including credit ratings from Standard and Poor’s and Moody’s in determining the financial strength of an issuer. Investment Strategies for Managing Portfolios Concentrated Portfolios Triad manages client accounts by investing in a limited number of securities. Clients should consider the fact that the risk of a concentrated portfolio with limited diversification increases the possibility of substantial losses and depreciation of the portfolio in the event of an exogenous event, the concentrated stock or sector does not perform as expected, and/ or deteriorating economic or market circumstances domestically and/or internationally. Cash as a Strategic Asset Triad does not seek to time the market and strives to remain fully invested but may at times retain a large portion of client assets in cash or cash equivalents when a limited number of attractive investments are available. We maintain cash balances until suitable opportunities arise. Investment Strategies General Investment Strategies Triad’s general investment strategy is to seek capital growth and attempts to minimize the probability of permanent losses over the longer-term, with less emphasis on short-term market fluctuations. Triad typically maintains concentrated equity portfolios with generally 20 to 30 equity positions, as we believe our clients will benefit from our extensive independent research and conviction in our investment ideas. More specifically, depending on client investment objectives, we utilize multiple asset classes, market capitalizations, and sectors to provide diversification. Each portfolio composition is determined in 11 Triad Investment Management Part 2A Brochure  accordance with the clients’ investment objectives, risk tolerance, time horizon, and need for capital appreciation or income. We deal with any client restrictions on an account-by-account basis. Since Triad treats each client account uniquely, client portfolios with similar investment objectives and asset allocation goals may own different securities. Timing and tax factors also influence Triad’s investment decisions. We attempt to manage accounts in a similar manner but occasionally clients who buy or sell securities on the same day will generally receive different prices when the trades are not aggregated. General Risk of Loss Statement Prior to entering into an agreement with Triad, the client should carefully consider: 1. That investing in securities involves risk of loss which clients should be prepared to bear; 2. That securities markets experience varying degrees of volatility; 3. That over time the value of a client’s assets will fluctuate and at any time be worth more or less than the amount invested; and 4. That clients should only commit assets that they feel are currently unneeded and available to Triad for investment on a long-term basis. This is typically a minimum of five to seven years. Risks General Risks of Owning Securities The prices of securities held in client accounts and the income they generate may decline in response to certain events taking place around the world. These include events directly involving the issuers of securities held in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations also affect security prices and income. The prices of, and the income generated by, most debt securities held by a client’s account are generally affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities in the client’s account generally will decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call” or refinance a security before its stated maturity, which can potentially result in Triad having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities generally have higher rates of interest and are often subject to greater price fluctuations than shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest, which can cause the security to go into default. The guarantee of a security backed by the U.S. Treasury, or the full faith and credit of the U.S. government only covers the timely payment of interest and principal when held to maturity. This means that the current market values for these securities will fluctuate with changes in interest rates. 12 Triad Investment Management Part 2A Brochure  Investments in securities issued by entities based outside the United States may be subject to increased levels of the risks described above. Currency fluctuations and controls, different accounting, auditing, financial reporting, disclosure, regulatory and legal standards, and practices could also affect investments in securities of foreign issuers. Equity Securities Equity securities represent an ownership position in a company. Equity securities typically consist of common stocks. The prices of equity securities fluctuate based on, among other things, events specific to their issuers and market, economic and other conditions. There may be little trading in the secondary market for particular equity securities, which may adversely affect Triad’s ability to dispose of such equity securities. Adverse publicity and investor perceptions, whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity securities. Small Capitalization Equity Securities Investing in smaller companies may pose additional risks as it is often more difficult to dispose of small company stocks, more difficult to obtain information about smaller companies, and the prices of their stocks may be more volatile than stocks of larger, more established companies. Clients should have a long-term perspective and, for example, be able to tolerate potentially sharp declines in value. Exchange-Traded Funds (ETFs) An exchange-traded fund (“ETF”) is a type of Investment Company (usually, an open-end fund or unit investment trust) typically containing a basket of equities, fixed income instruments, and/or commodities. ETFs may be structured to track the performance of a particular market index, including broad-based or sector-specific indexes. These “passive” ETFs seek to achieve investment results that correspond, before fees and expenses, to the performance of the underlying index by generally holding the same securities, or a representative sample of the securities, included in the index. However, such ETFs may not perfectly track their target index due to fees, expenses, tracking error, market conditions, or portfolio rebalancing. Other ETFs do not seek to replicate the performance of a specific index and instead rely on active portfolio management. Actively managed ETFs may invest in a more limited number of securities, may deviate significantly from market indexes, and may underperform or outperform the broader market depending on market conditions and the effectiveness of the investment manager’s strategies. Unlike traditional mutual funds, which can only be redeemed at the end of a trading day, ETFs trade throughout the day on an exchange. Like mutual funds, the prices of the underlying securities and the overall market generally affect ETF prices. Similarly, factors affecting a particular industry segment typically affect ETF prices that track that particular sector. Closed-end Funds Closed-end funds do not continually offer their shares for sale. Rather, they sell a fixed number of shares at an initial offering, after which the shares typically trade on a secondary market, such as the New York Stock Exchange or the NASDAQ Stock Market. Risk factors pertaining to closed-end funds vary from fund to fund. In addition, they may be subject to valuation risk, which is when common shares may trade above (a premium) or below (a discount) the net asset value (NAV) of the trust/fund’s portfolio. At 13 Triad Investment Management Part 2A Brochure  times, discounts could widen, or premiums could shrink, and could either dilute positive performance or compound negative performance. There is no assurance that discounted funds will appreciate to their NAV. Real Estate Investment Trusts Triad may invest for client accounts in securities issued by real estate investment trusts (REITs), which primarily invest in real estate or real estate-related loans. Equity REITs own real estate properties, while mortgage REITs hold construction, development and/or long-term mortgage loans. Changes in the value of the underlying property of the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory requirements, such as those relating to the environment, all can affect the values of REITs. Both types of REITs are dependent upon management skill, the cash flows generated by their holdings, the real estate market in general, and the possibility of failing to qualify for any applicable pass-through tax treatment or failing to maintain any applicable exemptive status afforded under relevant laws. American Depository Receipts (ADRs) An ADR is a stock that trades in the United States but represents a specified number of shares in a foreign corporation. Investors buy and sell ADRs on American markets just like regular stocks. Banks and brokerage firms issue/sponsor ADRs. ADRs are subject to additional risks of investing in foreign securities, including, but not limited to, less complete financial information available about foreign issuers, less market liquidity, more market volatility, and political instability. In addition, currency exchange-rate fluctuations affect the U.S. dollar-value of foreign holdings. Some ADRs and ordinary shares of foreign securities pay dividends, and many foreign countries impose dividend withholding taxes up to 30%. Depending on a custodian’s ability to reclaim any withheld foreign taxes on dividends, taxable accounts may be able to recoup a portion of these taxes by use of the foreign tax credit. However, tax-exempt accounts, to the extent they pay any foreign withholding taxes, may not be able to utilize the foreign tax credit. Therefore, investors may be unable to recover any foreign taxes withheld on dividends of foreign securities or ADRs. Debt Securities (Bonds) Issuers use debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Additional risks include issuer default risk which would reduce or eliminate interest payments and principal repayment, call provisions that could result in principal repayment prior to the bond stated maturity date, and liquidity risks, or the reduced ability to sell a bond prior to maturity. Triad attempts to mitigate these risks through issuer credit analysis to understand the bond issuer’s ability to make interest and principal payments. Triad attempts to reduce call risk through the purchase of bonds with call protection where possible, and liquidity risks are managed through understanding the bond issue liquidity prior to purchase. 14 Triad Investment Management Part 2A Brochure  Business Development Companies (BDCs) A business development company (BDC) is an organization that invests in small- and medium-sized companies. A BDC seeks to help the small- and medium-sized firms grow in the initial stages of their development. The BDCs we typically invest in are traded on major stock exchanges. BDCs do not continually offer their shares for sale. Rather, they sell a fixed number of shares at an initial offering, after which the shares typically trade on a secondary market, such as the New York Stock Exchange or the NASDAQ Stock Market. Risk factors pertaining to BDCs vary from company to company. In addition, they may be subject to valuation risk, which is when common shares may trade above (a premium) or below (a discount) the net asset value (NAV) of the BDC’s portfolio. At times, discounts could widen, or premiums could shrink, and could either dilute positive performance or compound negative performance. There is no assurance that discounted BDCs will appreciate to their NAV. LIBOR discontinuation In March 2021, regulators announced the future cessation of various London Interbank Offered Rates (LIBOR) rates. Certain rates are set to cease publication in December 2021 and others in June 2023; however, U.S. banking regulators have stated that new financial contracts may not utilize LIBOR after Dec. 31, 2021. The closed-end funds (CEF) and business development companies (BDC) Triad holds and continues to invest in some clients’ accounts are generally structured to utilize rates publicized by LIBOR. We do not see LIBOR’s discontinuation as adding a significant amount of risk or material to clients holding CEF & BDC investments; however, Triad will continue to monitor the LIBOR discontinuation and its potential impact going forward as alternative rates are substituted in the investments we hold and transact in on behalf of our clients. Cash and Cash Equivalents Client accounts often hold some cash or invest in cash equivalents, which are the most liquid of investments. Cash and cash equivalents are considered very low-risk investments meaning there is little risk of losing the principal investment. Typically, low risk also means low return and the interest an investor can earn on this type of investment is low relative to other types of investing vehicles. Financial Planning Risk The financial planning tools Triad uses to create financial plans for clients rely on various assumptions, such as estimates of inflation, risk, economic conditions, and rates of return on security asset classes. Return assumptions use asset class returns, not returns of actual investments, and do not generally include fees or expenses that clients would pay if they invested in specific products. Financial planning software is only a tool used to help guide Triad and the client in developing an appropriate plan, and we cannot guarantee that clients will achieve the results shown in the plan. Results will vary based on the information provided by the client regarding the client’s assets, risk tolerance, and personal information. Changes to the program’s underlying assumptions or differences in actual personal, economic, or market outcomes will generally impact client results. Clients should carefully consider the assumptions and limitations of the financial planning software and should discuss the results of the plan with us before making any changes to their financial plan. If the 15 Triad Investment Management Part 2A Brochure  financial plan includes recommendations for investing in securities, you should understand that investing in securities involves risk of loss, and you should be prepared to bear that risk. Other Risks Cybersecurity Information and technology systems can be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltrations by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although we have implemented various measures to manage risks relating to these types of events, if these systems are compromised, or become inoperable for extended periods of time, or cease to function properly, we may have to make a significant investment to fix or replace them. The failure of these systems can cause significant interruptions in our operations and result in a failure to maintain the security, confidentiality or privacy or sensitive data, including personal information relating to clients. Such a failure could potentially harm our reputation, subject us to legal claims, and otherwise have an adverse impact on our ability to perform advisory functions. Pandemics and Other Public Health Crises Pandemics and other health crises, such as the outbreak of an infectious disease such as severe acute respiratory syndrome, avian flu, H1N1/09 flu and COVID-19 or any other serious public health concern, together with any resulting restrictions on travel or quarantines imposed, could have a negative impact on the economy, and business activity in any of the areas in which client investments may be located. Such disruption, or the fear of such disruption, could have a significant and adverse impact on the securities markets, lead to increased short-term market volatility or a significant market downturn, and can have adverse long-term effects on world economies and markets generally. ITEM 9 – DISCIPLINARY INFORMATION Triad and our personnel seek to maintain the highest level of business professionalism, integrity, and ethics. Triad does not have any disciplinary information to disclose. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Triad does not offer any other services or have any affiliates in the financial industry. We are required to disclose any other financial industry activities and affiliations. The details are as follows: Affiliated Broker-Dealer Neither Triad nor any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Futures Commission Merchant Neither Triad nor any of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or is an associated person of the foregoing entities. 16 Triad Investment Management Part 2A Brochure  Relationships or Arrangements that are Material to Our Advisory Business Triad does not have any outside relationships or arrangements that are material to our advisory business. Selection of Outside Investment Advisers Triad does not select other advisers for its clients. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics Triad believes that we owe clients the highest level of trust and fair dealing. Further, as part of our fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our personnel. Triad’s personnel are required to conduct themselves with integrity at all times and follow the principles and policies detailed in our Code of Ethics. Triad’s Code of Ethics attempts to address specific conflicts of interest that either we have identified or that could likely arise. Triad’s personnel are required to follow clear guidelines from the Code of Ethics in areas such as gifts and entertainment, other business activities, and adherence to applicable state and federal securities laws. All personnel receive a copy of each amendment of the Code of Ethics, which they acknowledge in writing. Additionally, individuals who make securities recommendations to clients, or who have access to nonpublic information regarding any clients’ purchase or sale of securities are subject to personal trading policies governed by the Code of Ethics (see below). Triad will provide a complete copy of the Code of Ethics to any client or prospective client upon request. Personal Trading Practices Triad and our personnel purchase or sell securities for themselves that we also recommend to clients. This includes related securities (e.g., options, futures). This presents a potential conflict of interest as we may have an incentive to favor our personal trades over client transactions or use the information about the transactions we intend to make for clients to our personal benefit. Our policies to address these conflicts include the following: 1. Triad prohibits trading in a manner that takes personal advantage of price movements caused by client transactions. 2. If we wish to purchase or sell the same security as we recommend or take action to purchase or sell for a client, we will not do so until the custodian fills client orders (except when we are aggregating personal and proprietary trades with client trades as disclosed under Aggregation with Client Orders below). Because of this policy, it is possible that clients will receive a better or worse price than Triad or any employee for the same security on the same day as a client, or one or more days before or after the Client’s transaction. 17 Triad Investment Management Part 2A Brochure  3. Conflicts of interest also may arise when Triad’s personnel become aware of Limited Offerings or IPOs, including private placements or offerings of interests in limited partnerships or any thinly traded securities, whether public or private. Given the inherent potential for conflict, Limited Offerings and IPOs demand extreme care. We will provide the client with the opportunity to act on such investments, to the extent they are appropriate for the client’s risk and return objectives, prior to and in preference to Triad or our personnel. Triad will provide a complete copy of the Code of Ethics to any client or prospective client upon request. ITEM 12 – BROKERAGE PRACTICES Factors Considered in Selecting Broker-Dealers for Client Transactions Triad requires clients to open one or more custodian accounts in their own name at a qualified custodian. For clients in need of brokerage or custodial services, Triad generally recommends the use of Fidelity Institutional Wealth Services, a division of Fidelity Brokerage Services, Inc. (“Fidelity”), registered broker-dealer, Member SIPC. Further, we will also consider working with another custodian that the client chooses. The client will enter into a separate agreement with the broker-dealer/custodian to custody the assets. Triad is independently owned and operated and unaffiliated with any broker- dealer/custodian. Fidelity generally charges commissions (ticket charges) for executing our transactions. We do not receive any part of these separate charges. We require that clients establish accounts with Fidelity to maintain custody of clients’ assets and to effect trades for their accounts. Fidelity provides us with access to their institutional trading and custody services, which are typically not available to Fidelity retail investors. Fidelity’s services include brokerage custody, trading platforms and related services, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Fidelity does not charge clients separately for custody, but Fidelity receives compensation from account holders through commissions, other transaction-related fees, and/or securities trades executed through Fidelity or that settle into Fidelity. Triad considers several factors in recommending Fidelity to clients. Factors that we may consider include ease of use, reputation, trade execution, pricing, dedicated service team, and financial strength. Triad may also take into consideration the availability of the products and services received or offered (detailed below) by Fidelity. Research and Other Benefits Fidelity makes available to us other products and services that can potentially benefit Triad but may not directly benefit our clients’ accounts. These types of services will help us in managing and administering client accounts. These include software and other technology that provide access to client account data (i.e., trade confirmations and account statements); facilitate trade executions; provide research, pricing information, and other market data; facilitate in the payment of our fees from clients’ accounts; and assist with back-office functions, record keeping, and client reporting. Many of these services may be used to service all or a substantial number of our accounts. 18 Triad Investment Management Part 2A Brochure  We place trades for our clients’ accounts subject to our duty to seek best execution and other fiduciary duties. Generally, trades are placed through Fidelity due to the additional costs associated with using broker-dealers other than Fidelity to execute trades for client accounts maintained at Fidelity. Fidelity’s execution quality may be different from other broker-dealers. Fidelity may also provide other benefits such as educational events, conferences on practice management, regulatory compliance, information technology, and business success. Fidelity may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to Triad. As part of our fiduciary duties to clients, Triad endeavors at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by Triad or our personnel in and of itself creates a potential conflict of interest and may indirectly influence Triad’s recommendation of Fidelity for custody and brokerage services. Fixed Income Transactions We will generally use broker-dealers other than the client’s broker-dealer/custodian to execute bond trades when the execution we receive from these bond brokers after the deduction of the additional “prime broker” or “trade away” fees will net a lower cost or better price for the client than if the broker- dealer/custodian executed the trade. As another benefit to the client, prime brokerage arrangements allow clients to participate in block trades, which may provide more favorable execution than when a client does not participate in a block trade. We do not involve clients in prime brokerage arrangements without their prior written authorization. Prime brokerage arrangements are only available to accounts that meet the minimum net equity requirements established by the SEC. Prime Brokers may impose net equity requirements higher than those established by the SEC. Brokerage for Client Referrals Triad does not receive client referrals from any broker-dealer or third party in exchange for using that broker-dealer or third party. Directed Brokerage Triad does not allow clients to direct Triad to use a specific broker-dealer to execute transactions. Clients must use the broker-dealers that Triad requires to custody their account(s) to execute transactions. Triad makes an exception to this policy to honor prior agreements. Not all investment advisers require their clients to trade through specific brokerage firms. By requiring clients to use Fidelity, Triad believes we may be able to more effectively manage the client’s portfolio, achieve favorable execution of client transactions, and overall lower the costs to the portfolio. Since we require most of our clients to maintain their accounts with Fidelity, it is also important for clients to consider and compare the significant differences between having assets custodied at another broker-dealer, bank, or other custodian prior to opening an account with us. Some of these differences include, but are not limited to total account costs, trading freedom, transaction fees/commission rates, and security and technology services. 19 Triad Investment Management Part 2A Brochure  Clients with 401(k) accounts are not required to use Fidelity and may appoint a custodian of their choosing. Aggregation and Allocation of Transactions Triad aggregates orders for clients in the same securities in an effort to seek best execution, negotiate more favorable commission rates, and/or allocate differences in prices, commissions, and other transaction costs equitably among our clients. These are benefits of aggregation orders that we might not obtain if we placed those orders independently. Triad will generally allocate the proceeds arising out of those transactions (and the related transactions expenses) on an average price basis among the various participants in the transactions. Triad believes that combining orders in this way will be advantageous to all participants. However, the average price could be less advantageous to a particular client than if that client had been the only account effecting the transaction or had completed its transaction before the other participants. Triad may also place orders for the same security for different clients at different times and in different relative amounts due to, among other things, differences in investment objectives, cash availability, size of order, and practicability of participating in “block” transactions. The level of participation by different clients in the same security may also be dependent upon other factors relating to the suitability of the security for the particular client. There are circumstances when some of a client’s transactions in the security may not be aggregated with other clients. Triad has adopted policies and procedures intended to ensure that our trading allocations are fair to all of our clients. In addition, Triad and/or our personnel may buy or sell specific securities for our own accounts that are not deemed appropriate for another client at the time, based on personal investment considerations that differ from the considerations on which decisions as to investments for the client are made. Where execution opportunities for a particular security are limited, Triad attempts in good faith to allocate such opportunities among clients in a manner that, over time, is equitable to all our clients. Triad aggregates trades in like securities among client accounts as well as with accounts of Triad and our personnel, if we follow the policies described below. This presents a potential conflict of interest as we may have an incentive to allocate more favorable executions to our own accounts or the accounts of our personnel. Our policies to address this conflict are as follows: 1. We disclose our aggregation policies in this brochure; 2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty to seek best execution (which includes the duty to seek best price) for our clients. The trade also needs to be consistent with the terms of our investment advisory agreement with each client that has an account included in the aggregation; 3. No account will be favored over any other account. This includes accounts of Triad or any of our personnel. Each account in aggregated trade will participate at the average share price for all of our transactions in a given security on a given business day (per custodian). 20 Triad Investment Management Part 2A Brochure  4. Before entering an aggregated order, we will prepare a written statement (the “Allocation Statement”) specifying the participating accounts and how we intend to allocate the order among those accounts; 5. If the aggregated order is filled entirely, we will allocate shares among clients according to the Allocation Statement; if the order is partially filled, we will allocate it pro-rata according to the Allocation Statement. Further, fixed income trades can be allocated based upon any or all of the following considerations: each client’s custom portfolio strategy, current and future financial needs, the account’s asset allocation, diversification, tax considerations, levels of cash, and newly opened accounts which may need to be invested; 6. However, we may allocate the order differently than specified in the Allocation Statement if all client accounts receive fair and equitable treatment. (See also Item 12 – Brokerage Practices below.) In this case, we will explain the reasons for a different allocation in writing. 7. If an aggregated order is partially filled and we allocate it differently than the Allocation Statement specifies, no participating account may purchase or sell the security for a reasonable period following the execution of the block trade. This only applies when the participating account sells or receives more shares than it would have if the aggregated order had been completely filled; 8. Our books and records will separately reflect each aggregated order and the securities held by, bought, and sold for each client account; 9. Funds and securities of clients participating in an aggregated order will be deposited with one or more qualified custodians. Clients’ cash and securities will not be held collectively any longer than is necessary to settle the trade on a delivery versus payment basis. Following settlement, cash or securities held collectively for clients will be delivered out to the qualified custodian as soon as practical; 10. We do not receive additional compensation or remuneration of any kind as a result of aggregating orders; and 11. We will provide individual investment advice and treatment to each client’s account. ITEM 13 – REVIEW OF ACCOUNTS Managed Account Reviews Triad monitors securities in client accounts continuously. Typically, we also review cash balances and asset allocations at least weekly and often daily. Material market, economic, or political events, changes in a client’s individual circumstances may trigger additional reviews. John Heldman, Partner, and David Hutchison, Partner, perform all reviews and generally meet with each client at least annually. 21 Triad Investment Management Part 2A Brochure  Account Reporting Each client receives a written statement from the broker-dealer/custodian that includes an accounting of all holdings and transactions in the account for the reporting period. In addition, Triad provides a review letter and account report on a quarterly basis. Review letters typically include a review of the investment environment and economic outlook. Account reports include a summary of the client’s holdings and account performance. Triad may also provide additional reporting as agreed upon by Triad and the client on a case-by-case basis. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Client Referral Fees Triad engages third-party marketing and lead generation service providers to introduce prospective clients to our firm. These arrangements are governed by written agreements and are designed to comply with Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The lead generation service providers we engage are not clients of Triad. They do not provide investment advice on our behalf and are not authorized to negotiate our advisory agreements. The lead generation providers are compensated through flat fees, subscription fees, or other fixed compensation arrangements. Compensation is not based on the number of clients retained, assets placed under management, or advisory fees generated by any particular prospective client. Triad does not pay compensation that is contingent upon a prospective client entering into an advisory agreement and we do not charge referred clients higher advisory fees as a result of these arrangements. Triad’s payment of fees to a lead generation provider creates a conflict of interest because the provider has a financial incentive to present Triad in a favorable light and to encourage prospective clients to contact us. Prospective clients are encouraged to independently evaluate Triad’s qualifications and services before entering into an advisory relationship. Outside Referrals Triad may refer clients to unaffiliated professionals for specific needs, such as legal, and/or tax/accounting services. In turn, these professionals may refer clients to Triad for investment management. We do not have any agreements with individuals or companies that we refer clients to, and we do not receive any compensation for these referrals. However, it could be concluded that Triad is receiving an indirect economic benefit from the arrangement, as the relationships are mutually beneficial. For example, there could be an incentive for us to recommend services of firms who refer clients to Triad. Triad only refers clients to professionals we believe are competent and qualified in their field, but it is ultimately the client’s responsibility to evaluate the provider, and it is solely the client’s decision whether to engage a recommended firm. Clients are under no obligation to purchase any products or services through these professionals, and Triad has no control over the services provided by another firm. Clients who choose to engage these professionals will sign a separate agreement with the other firm. Fees charged by the other firm are separate from and in addition to fees charged by Triad. 22 Triad Investment Management Part 2A Brochure  If the client desires, Triad will work with these professionals or the client’s other advisors (such as an accountant or attorney) to help ensure that the provider understands the client’s investments and to coordinate services for the client. Triad does not share information with an unaffiliated professional unless first authorized by the client. ITEM 15 – CUSTODY Triad has limited custody of some of our clients’ funds or securities when the clients authorize us to deduct our management fees directly from the client’s account. A qualified custodian (generally a broker-dealer, bank, trust company, or other financial institution) holds clients’ funds and securities. Clients will receive statements directly from your qualified custodian at least quarterly. The statements will reflect the client’s funds and securities held with the qualified custodian as well as any transactions that occurred in the account, including the deduction of Triad’s fee. Triad relies on the following safeguards: 1. Triad has custody of the funds and securities solely as a consequence of its authority to make withdrawals from client accounts to pay its advisory fee. 2. Triad has written authorization from the client to deduct advisory fees from the account held with the qualified custodian. 3. Each time a fee is directly deducted from a client account, the Triad concurrently: a. Sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the client's account; and b. Sends the client an invoice or statement itemizing the fee. Itemization includes the formula used to calculate the fee, the value of the assets under management on which the fee is based, and the time period covered by the fee. Triad is also deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and under that SLOA authorize us to designate the amount or timing of transfers with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. Clients should carefully review the account statements you receive from your qualified custodian. When clients receive statements from Triad as well as from the qualified custodian, clients should compare these two reports carefully. Minor discrepancies between custodian statements and Triad statements are common. Triad uses trade date for transactions while custodians generally use settlement date. In addition, custodians occasionally use a different bond pricing service than Triad (on rare occasions, Triad also prices bonds internally), which generally results in minor price differences. Clients with any questions about your statements should contact us at the address or phone number on the cover of this brochure. Clients who do not receive their statement from your qualified custodian at least quarterly should also notify us. ITEM 16 – INVESTMENT DISCRETION Triad has full discretion to decide the specific security to trade, the quantity, the timing of transactions for client accounts, and generally the custodian through which transactions will be placed. Triad will not contact clients before placing trades in their account, but clients will receive confirmations directly from 23 Triad Investment Management Part 2A Brochure  the broker for any trades placed unless they have chosen to disable trade alerts in their account. Clients grant us discretionary authority in the contracts they sign with us. Clients also give us trading authority over their accounts when they sign the custodian paperwork. However, certain client-imposed conditions may limit Triad’s discretionary authority, such as where the client prohibits transactions in specific security types. See also Item 4 – Tailored Services and Client Imposed Restrictions and Item – 12 Brokerage Practices, above. ITEM 17 – VOTING CLIENT SECURITIES Proxy Voting Triad has a policy of voting proxies for securities held in client accounts. We will only cast proxy votes in a manner consistent with the best interests of our clients. Absent special circumstances, which we describe in our Proxy Voting Policies and Procedures, we will vote all proxies within Triad’s established guidelines, which we may amend from time-to-time. Except in rare circumstances (see below), we do not allow clients to direct our vote in particular solicitations. At any time, clients may contact us to request information about how we voted your proxies for your securities or to get a copy of our Proxy Voting Policies and Procedures. A brief summary of Triad’s Proxy Voting Policies and Procedures is as follows: We apply our Proxy Voting Guidelines with a measure of flexibility. Further, we may vote a proxy contrary to the Proxy Voting Guidelines if we determine that the action is in the best interests of our clients. In exercising our voting discretion, we may take into account a wide array of factors relating to the matter under consideration, the nature of the proposal, and the company involved. Similarly, poor past performance, uncertainties about management and future directions, and other factors may lead to the conclusion that particular proposals by an issuer present unacceptable investment risk and should not be supported. Triad may occasionally be subject to conflicts of interest in the voting of proxies due to business or personal relationships it maintains with persons having an interest in the outcome of certain votes. If we become aware of any type of potential or actual conflict of interest relating to a particular proxy proposal, we will promptly document and handle the conflict as follows: 1. Where the Proxy Voting Guidelines outline our voting position, either “for” or “against” the proxy proposal, voting will be in accordance with our Proxy Voting Guidelines. 2. Where the Proxy Voting Guidelines outline our voting position to be determined on a “case by case” basis for the proxy proposal, or the proposal is not listed in the Proxy Voting Guidelines, then we will select one of the two following methods depending upon the facts and circumstances of each situation and the requirements of applicable law: a. Voting the proxy in accordance with the voting recommendation of a non-affiliated-third party vendor; or b. Voting the proxy according to the client’s direction. In certain circumstances, we may choose not to vote proxies in certain situations or for certain accounts: 24 Triad Investment Management Part 2A Brochure  1. Where we believe that the cost of voting would exceed any anticipated benefit to the client; 2. Where we receive a proxy for a terminated client account, we will notify the custodian and request that the custodian send current and future proxy materials to the account address of record; and/or 3. Where a proxy is received for a security that we no longer manage (e.g., we previously sold the entire position). Class Actions Triad utilizes a third-party service provider to provide class action litigation monitoring and securities claim filing services. For a contingency fee, the provider secures class action claims, monitors each client’s claim, collects the applicable trade history, interprets the terms of each settlement, files the appropriate claim form, interacts with the administrators, and distributes awards on the client’s behalf. In order to perform the above services, we make certain client nonpublic information available to the service provider, including but not limited to beneficial ownership and social security number. Clients may opt out of the above service upon request. When applicable, clients that subsequently terminate management services must contact the third-party class action service provider directly to receive settlement payments for positions held while under our management. ITEM 18 – FINANCIAL INFORMATION Registered investment advisers are required in this item to provide clients with certain financial information or disclosures about the firm’s financial condition. Triad does not require the prepayment of more than $1,200 in fees per client six months or more in advance, does not foresee any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients, and has never been the subject of a bankruptcy petition. 25 Triad Investment Management Part 2A Brochure  Form ADV, Part 2B Brochure Supplement John Heldman, CFA® (CRD # 3276168) David Hutchison, CFA® (CRD # 2602539) Triad Investment Management, LLC 1301 Dove Street Suite 1080 Newport Beach, CA 92660 (949) 679-3991 March 30, 2026 This brochure supplement provides information about John Heldman and David Hutchison that supplements the Triad Investment Management, LLC brochure. You should have already received a copy of that brochure. Please contact David Hutchison at (949) 679-3991 or dhutchison@triadim.com if you did not receive our brochure or if you have any questions about the contents of this supplement. Additional information about John Heldman and David Hutchison is available on the SEC’s website at www.adviserinfo.sec.gov. IT ITEM 1 - COVER PAGE  John Heldman ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE John E. Heldman, Partner, b. 1958 Education: • B.S., Finance, California State University, Long Beach, 1984 • MBA, California State University, Long Beach, 1987 • Chartered Financial Analyst®, CFA Institute, 1989 Business Background: John Heldman is the founder of Triad. Prior to founding Triad, John served as a Senior Vice President and Portfolio Manager for Neuberger Berman, LLC in Newport Beach for three years. Prior to that, beginning in June of 1999, he worked for Scudder Investor Services, Inc., which was acquired by Deutsche Bank. He was both a registered representative of Deutsche Bank Securities, Inc. and a Vice President and Portfolio Manager when he departed in November 2004. In September 1988, John was employed by Security Pacific Bank, which was acquired by Bank of America. John left Bank of America in June 1999 and was a Vice President and Portfolio Manager at that time. Professional Designations Chartered Financial Analyst The Chartered Financial Analyst® (“CFA®”) designation is sponsored by the CFA Institute. To earn a CFA® charter, candidates must have four years of qualified investment work experience, become a member of CFA Institute, pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct on an annual basis, apply for membership to a local CFA® member society, and complete the CFA® Program. The CFA Program® is organized into three levels, each culminating in a six-hour exam. The three proctored course exams correspond to three 250-hour self-study levels. Completing the Program takes most candidates between two and five years. More information regarding the CFA® is available at https://www.cfainstitute.org. ITEM 3 - DISCIPLINARY INFORMATION John Heldman has no disciplinary history to disclose. ITEM 4 - OTHER BUSINESS ACTIVITIES John Heldman’s only business is providing investment advice through Triad. ITEM 5 - ADDITIONAL COMPENSATION John Heldman’s only compensation comes from his regular salary and ownership of Triad. ITEM 6 - SUPERVISION John Heldman, Partner, supervises all employees. John Heldman can be reached at the phone number on the cover page of this supplement. ii Triad Investment Management Part 2B Supplements  David Hutchison ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE David M. Hutchison, Partner, Chief Compliance Officer, b. 1970 Education: • B.A., Political Science, Macalester College, 1993 • MBA, University of Southern California, 2000 • Chartered Financial Analyst®, CFA Institute, 2002 Business Background: David Hutchison is Partner and Chief Compliance Officer at Triad. Prior to joining Triad in 2013, he served as Investment Strategist for Chamberlain Group, directing investment manager research since 2009. Prior to that, in 2005 he founded and managed Hutchison Capital, a registered investment advisor. From 2000-2005, he served as Equity Research Analyst for Insight Capital Research & Management, a registered investment advisor. Professional Designations Chartered Financial Analyst The Chartered Financial Analyst® (“CFA®”) designation is sponsored by the CFA Institute. To earn a CFA® charter, candidates must have four years of qualified investment work experience, become a member of CFA Institute, pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional Conduct on an annual basis, apply for membership to a local CFA® member society, and complete the CFA® Program. The CFA® Program is organized into three levels, each culminating in a six-hour exam. The three proctored course exams correspond to three 250-hour self-study levels. Completing the Program takes most candidates between two and five years. More information regarding the CFA® is available at https://www.cfainstitute.org. ITEM 3 - DISCIPLINARY INFORMATION David Hutchison has no disciplinary history to disclose. ITEM 4 - OTHER BUSINESS ACTIVITIES In addition to providing investment advice through Triad, David Hutchison serves as a member of CalOptima Health’s Investment Advisory Committee where he helps oversee the investment consultant and two outside managers that manage primarily corporate cash for CalOptima Health. Mr. Hutchison spends approximately 2 hrs./qtr. on this activity and is not compensated for his time. ITEM 5 - ADDITIONAL COMPENSATION David Hutchison’s only compensation comes from his regular salary and ownership of Triad. iii Triad Investment Management Part 2B Supplements  ITEM 6 - SUPERVISION John Heldman, Partner, supervises all employees. John Heldman monitors the advice provided by David Hutchison for consistency with client objectives and Triad’s policies. John Heldman can be reached at the phone number on the cover page of this supplement. iv Triad Investment Management Part 2B Supplements  Rev. March 2013 Client Privacy Notice FACTS WHAT DOES TRIAD INVESTMENT MANAGEMENT, LLC (“TRIAD”) DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. Why? Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the What? product or service you have with us. This information can include: Social Security number and income • • account balances and transaction history • assets and risk tolerance When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to How? run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Triad chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Triad share? Can you limit this sharing? For our everyday business purposes - YES NO as permitted by law For our marketing purposes - to offer our products and NO We Don’t Share services to you For joint marketing with other financial companies NO We Don’t Share For our affiliates’ everyday business purposes - NO We Don’t Share information about your transactions and experiences For our affiliates’ everyday business purposes - NO We Don’t Share information about your creditworthiness For nonaffiliates to market to you NO We Don’t Share Questions? Call (949) 679-3991 or go to www.triadim.com  Page 2 WHO WE ARE Who is providing this notice? Triad Investment Management, LLC WHAT WE DO How does Triad protect my To protect your personal information from unauthorized personal information? access and use, we use security measures that comply with federal law. These measures include computer safeguards and secure files and buildings. How does Triad collect my We collect your personal information, for example, when you personal information? seek advice about your investments tell us about your investment or retirement portfolio tell us about your investment or retirement earnings • • enter into an investment advisory contract • • • give us your contact information We also collect your personal information from other companies. Why can’t I limit all sharing? Federal law gives you the right to limit only: • sharing for affiliates’ everyday business purposes - information about your creditworthiness sharing for nonaffiliates to market to you • affiliates from using your information to market to you • State laws and individual companies may give you additional rights to limit sharing. DEFINITIONS Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. Triad Investment Management, LLC has no affiliates • Nonaffiliates Companies not related by common ownership or control. They can be financial and non-financial companies. • Triad Investment Management, LLC does not share with nonaffiliates so they can market to you Joint Marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. • Triad Investment Management, LLC does not jointly market