TRINITY NECHES

Thiel Investment Management Company, LLC DBA Trinity Neches Form ADV Part 2 Brochure This Brochure provides information about the qualifications and business practices of Thiel Investment Management Company, LLC DBA Trinity Neches. If you have any questions about the contents of this Brochure, please contact us at 713-248-8129. 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. Additional information about Thiel Investment Management Company, LLC DBA Trinity Neches is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Thiel Investment Management Company, LLC DBA Trinity Neches is 282631. Trinity Neches is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. 7910 Mountain Laurel Lane Sugar Land, Texas 77479 Phone: 713-248-8129 Brochure date: April 2026  Item 2 – Material Changes Since our last delivery or posting of this document on the SEC’s public disclosure website, the firm is registering with the SEC. We will further provide you with a new Brochure, as necessary, based on changes or new information, at any time and without charge. Currently, our Brochure may be requested by contacting Milton “Chip” Thiel, Jr., Manager and Chief Compliance Officer, at 713-248-8129 or Chip@TrinityNeches.com.  Item 3 - Table of Contents Item 2 – Material Changes ......................................................................................................................... ii Item 3 - Table of Contents ......................................................................................................................... iii Item 4 - Advisory Business ........................................................................................................................ 1 Item 5 - Fees and Compensation .............................................................................................................. 2 Item 6 - Performance-Based Fees and Side-By-Side Management ....................................................... 5 Item 7 - Types of Clients ............................................................................................................................ 5 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 5 Item 9 - Disciplinary Information ............................................................................................................... 7 Item 10 - Other Financial Industry Activities and Affiliations ................................................................ 7 Item 11 - Code of Ethics Participation or interest in Client Transactions and Personal Trading ...... 8 Item 12 - Brokerage Practices ................................................................................................................... 8 Item 13 - Review of Accounts .................................................................................................................. 11 Item 14 - Client Referrals and Other Compensation ............................................................................. 11 Item 15 - Custody ...................................................................................................................................... 12 Item 16 - Investment Discretion .............................................................................................................. 12 Item 17 - Voting Client Securities ............................................................................................................ 13 Item 18 - Financial Information ................................................................................................................ 13  Item 4 - Advisory Business Thiel Investment Management Company, LLC DBA Trinity Neches (“Trinity Neches”, “the Firm”, “Our” or ‘We”) is located in Sugar Land, Texas and was founded in 2016 by Milton “Chip” Thiel, Jr. The principal business of Trinity Neches is providing advisory services to clients. This activity includes continuous advice concerning investment of money consistent with the objectives of each client. Private Wealth Management Advisory Services Trinity Neches provides discretionary advisory services by investing in securities that the Firm believes are in the best interest of each client based on their investment objectives, risk tolerance and other individual client needs and circumstances. Our Advisory Services are tailored to a client’s specific needs and goals through a dialogue concerning their assets, liabilities, income, expenses, goals, and objectives. A long-term investment plan is established, then reconfirmed or adjusted as needed. There is not a limit to the types of investments offered. In certain circumstances clients may impose restrictions on investing in certain securities or types of securities. Financial Planning Services We will provide financial planning services which include the following services: • Retirement Income Planning • Investment Planning • General Financial Planning • Estate Planning • Business Planning • Insurance Planning • Educational Fund Planning If the Client elects Financial Planning Services, we may extend the initial consultation to include discussions necessary to begin creating a financial plan or may arrange a follow-up meeting to review additional information about the Client’s finances. In any case, the Client will have the choice to: a) Consult with Trinity Neches on the Client’s overall financial situation and obtain a comprehensive, written financial plan; or b) Consult with Trinity Neches on a specific topic or an individual security. In creating a written financial plan for the Client, Client and Trinity Neches will follow this process: a) Client will provide Trinity Neches with financial and personal data necessary to prepare Client’s plan. An estimate of time required will be made after the facts are gathered. 1  b) Trinity Neches will analyze data and documents provided, evaluate Client’s ability to meet its objectives, make observations, identify problems, and recommend strategies for Client’s consideration. c) On the basis of the data Client provides and the objectives chosen, Trinity Neches will prepare and present a personal financial plan summarized in written form. Corporate Retirement Plan Services We offer services to 401K plans on a discretionary and non-discretionary basis, and in accordance with the objectives specified, and in accordance with the Investment Policy Statement of the Plan (“IPS”), if applicable. Services include: Plan design and implementation, on-going plan review and analysis, research and evaluation of plan investment choices, annual qualitative and quantitative analysis of investment choices, asset allocation strategies and discretionary management available to plan participants as outlined in separate independent Investment Advisory Agreement, group educational meetings for plan participants, recommend modifications based on changes in structure of employer, IRS Rules or as dictated by corporate executives, executive consultations regarding overall investment strategy and retirement planning. These services may be modified or revised from time to time, based on the approval of both parties. DOL Disclosure When we provide investment advice to you regarding your retirement plan account 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. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge is no more than reasonable for our services; and • Give you basic information about conflicts of interest. As of year-end 2025, the firm managed $120,387,810 in assets under management, $117,235,218 in discretionary assets and $3,152,592 in non-discretionary assets. Item 5 - Fees and Compensation The client pays Trinity Neches for its advisory services based upon the client's assets under management. Fees are calculated by multiplying the assets under management by the relevant percent and dividing such product by four (4). Private Wealth Management Accounts opened in mid-quarter will be assessed at a pro-rated management fee. Fees are payable quarterly, in arrears, and such fees may be deducted from client's account(s) quarterly within thirty (30) days following the end of the previous quarter for which said fees will be incurred. Quarterly fees are calculated at the annual rate, adjusted for the days in the cycle; contributions/distributions will be prorated. 2  Private Wealth Management Advisory Fees: The advisory fees payable to the Firm are a percentage of assets under management. The amounts and specific manner in which fees are charged is memorialized in our contract with the client. Trinity Neches is compensated through an annualized asset-based fee which will be paid quarterly in arrears. The valuation of securities and other instruments are generally determined by their last reported sale price on the principal market in which they are traded, if traded on a market for which transaction prices are publicly reported. Otherwise, other readily marketable securities and instruments are valued by using a pricing service or by other equitable means consistent with the fiduciary duty of the money manager to determine a fair market value. The fee schedule for this service is as follows: Fee schedule: Assets Rate The first $1,000,000 The next $4,000,000 Over $5M 1.00% 0.50% 0.25% Account Minimum: We generally require a $250,000 minimum of billable assets for the management of accounts but reserve the right to make exceptions on a case-by-case basis. We reserve the right to refuse to accept proposed management responsibilities and to resign from the management of any individual account. Veterans and active military will receive 25% discount to the standard fee schedule along with a reduced minimum account balance to $100,000 of billable assets. We maintain a Limited Power of Attorney for all discretionary accounts for directing and or effecting investments on behalf of the managed account and for the direct payment of our fees. Corporate Retirement Plan Services Fee schedule: Assets Rate 0.50% 0.30% 0.20% The first $1,000,000 The next $4,000,000 The next $5,000,000 Over $10M 0.13% Minimum Annual Fee is $5,000.00 Termination The relationship may be terminated by either party upon 10 days’ written notice. Since fees are paid in arrears, a final fee will be charged which will be prorated according to the number of days for which we provided service during the current quarter. Notwithstanding the above, if the appropriate disclosure statement was not delivered to the client at least 48 hours prior to the client entering into any written or oral advisory contract with this investment adviser, then the client has the right to terminate the relationship, contract without penalty, within five (5) business days after entering into the contract. 3  Financial Planning Fees: For written financial plans, we charge a fixed fee. Financial Planning Fees start at $5,000 and are adjusted based on the type and complexity of the financial plan. The final amount will be specified in the Financial Planning Agreement. One-half of the fee stated in the Financial Planning Agreement is due at signing. The balance shall be due and payable upon completion of the agreed upon services. If a Client chooses to terminate within ten (10) business days from the date of execution, client is entitled to a full refund. Clients may terminate at any time via written notice before the service is complete, we will charge a prorated amount for the work completed (based on how many hours utilized times $300 an hour). Notwithstanding the above, all fees are negotiable and certain clients may be charged less, depending upon a number of factors, including portfolio size, employment, and relationship to Advisor. Private Wealth Management Client Satisfaction Commitment If at any time or for any reason a client is not completely satisfied with our services, at the client’s request, we will refund the client’s advisory fee for the previous calendar quarter. The client will receive a credit to their account(s) within approximately four weeks of the request. No other fees, commissions, charges, expenses, or market losses will be refunded. Prior to the account(s) being refunded, the client must meet (in person) with a representative from the firm. Fee Payment Direct debiting: at the end of each calendar quarter, we will notify your custodian of the amount of the fee due and payable to us through our fee schedule and contract. The custodian does not validate, or check our fee, nor its calculation on the assets on which the fee is based. The custodian will “deduct” the fee from your account(s) or, if you have more than one, account from the account you have designated to pay our advisory fees. o At least quarterly, you will receive a statement directly from your custodian showing all transactions, positions, and credits/debits into or from your account, including the advisory fee paid by you to us. Additional Fees and Expenses Advisory fees payable to us do not include all the fees you will pay when we purchase or sell securities for your Account(s). The following list of fees or expenses are what you pay directly to third parties, whether a security is being purchased, sold, or held in your Account(s) under our management. Fees charged are by the broker dealer / custodian. We do not receive, directly or indirectly, any of these fees charged to you. They are paid to your broker, custodian or the mutual fund or other investment you hold. The fees include: • Transaction fees; • Exchange fees; • SEC fees; • Advisory fees and administrative fees charged by Mutual Funds (MF), Exchange Traded Funds (ETFs), Closed-End Funds (CEFs); • Advisory fees charged by sub-advisers (if any are used for your account); • Custodial Fees; • Odd-Lot differentials; • Transfer taxes; • Wire transfer and electronic fund processing fees; 4  • Commissions or mark-ups / mark-downs on security transactions; • Among others that may be incurred. Item 6 - Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Item 7 - Types of Clients We provide our services to a number of Clients: • Individuals, including high net worth individuals • Trusts, estates, and charitable organizations • Profit sharing plans • Corporations or other business entities Account Minimum: We generally require a $250,000 minimum of billable assets for the management of accounts but reserve the right to make exceptions on a case-by-case basis. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Analysis: Our security analysis methods include: Fundamental: Fundamental analysis maintains that markets may misprice a security in the short run, but that the "correct" price will eventually be reached by the market. The fundamental analysis of a business involves analyzing businesses: financial statements and health, management and competitive advantages, and competitors and markets. When applied to futures and forex, it focuses on the overall state of the economy, interest rates, production, earnings, and management. Technical: Technical analysis maintains that all information is already reflected in the stock price. Technical analysis is a discipline for forecasting the direction of prices through the study of past market data, primarily price and volume. Generally, technical analysis employs models and trading rules based on price and volume transformations, such as the relative strength index, moving averages, regressions, inter-market and intra-market price correlations, business cycles, stock market cycles or, classically, through recognition of chart patterns. Cyclical: Cyclical analysis generally targets cyclical stocks for purchase of equity securities when the ratio of price-to-earnings (P/E Ratio) is low and sell them when the P/E Ratio is high (i.e. when earnings are peaking). The P/E Ratio is a measure of the price paid for a share relative to the annual net income or profit earned by the firm per share. 5  Our Investment Strategies We offer several investment strategies to you and in doing so, we may invest in a wide range of securities and other financial instruments including: Interests in partnerships investing in real estate, oil and gas interests Interest and principal only strips • Equity securities • Exchange-listed securities • Over-the-counter securities • Securities of foreign issuers (including ADRs, EDRs and GDRs) • Warrants • Rights • Restricted shares • Local access products • Options contracts • Futures • Corporate debt • Commercial paper • Certificates of deposit • United States government securities • Municipal securities • Variable annuities and mutual funds • • Swaps • Forward contracts • Options on futures contracts • Cap options • Floor options • • Structured notes • Listed and over the counter derivatives • Mortgage related and other asset backed securities • Bank loans • Collateralized debt obligations • Collateralized mortgage obligations • Foreign currency forward agreements • Repurchase and reverse repurchase agreements • Private placements • Long term Purchases (securities held at least a year) • Short term purchases (securities sold within a year) General Risks Lack of Diversification: Portfolio investments may be concentrated, and diversification may be limited. There are no limits with respect to position sizes. Any assets or combination of assets that can be held in a securities account can be purchased or sold. Cash and Cash Equivalents: Accounts may maintain significant cash positions from time to time and the client will pay the Investment Management Fee based on the net asset value of the Account, including cash and cash equivalents. Furthermore, the Account may forego investment opportunities to hold cash positions if we considers it in the best interests of the Accounts. Interest Rate Fluctuation: The prices of securities in which the Advisor may invest are sensitive to interest rate fluctuations and unexpected fluctuations in interest rates could cause the corresponding prices of the long and 6  short portions of a position to move in directions which were not initially anticipated. In addition, interest rate increases generally will increase the interest carrying costs of borrowed securities and leveraged investments. Long term Purchases (securities held at least a year) Liquidity: The portfolio may be invested in liquid and illiquid securities. You should be aware that liquid securities may become less liquid during the holding period. Short term purchases (securities sold within a year) Market Risks: The success of a significant portion of the program will depend, to a great extent, upon correctly assessing the future course of the price movements of the securities traded. There can be no assurance that the trading program will be able to predict accurately these price movements. Additionally, over time, the effectiveness of the trading program may decline, including due to other market participants developing similar programs or techniques. As financial markets and products evolve, we may invest in other instruments or securities, whether currently existing or developed in the future, when consistent with client guidelines, objectives, and policies. Sources of Information In conducting security analysis, we utilize a broad spectrum of information, including financial publications, third- party research materials, annual reports, prospectuses, regulatory filings, company press releases, and corporate rating services. Risk of Loss All investments in securities include a risk of loss of your principal (invested amount) and any profits that have not been realized (the securities were not sold to “lock in” the profit). As you know, stock markets and bond markets fluctuate substantially over time. In addition, as recent global and domestic economic events have indicated, performance of any investment is not guaranteed. As a result, there is a risk of loss of the assets we manage that may be out of our control. We will do our very best in the management of your assets; however, we cannot guarantee any level of performance or that you will not experience a loss of your account assets. Investing in securities involves risk of loss that clients should be prepared to bear. Item 9 - Disciplinary Information Trinity Neches does not have any material information or facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. In an abundance of caution, Mr. Lovett has answered affirmatively to a disclosure on his U4. You may refer to Mr. Lovett’s Form U4 on https://adviserinfo.sec.gov/. Item 10 - Other Financial Industry Activities and Affiliations Trinity Neches does not have any other financial industry activities or affiliations. Please refer to the Firms 2B supplement for any of the Advisory Representatives outside activities. 7  Item 11 - Code of Ethics Participation or interest in Client Transactions and Personal Trading We have adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Trinity Neches must acknowledge the terms of the Code of Ethics annually, as amended. Trinity Neches requires trade confirmations and quarterly reporting of accounts. Personal Trading To mitigate conflicts of interest, all employees must comply with our Code of Ethics and procedures, which collectively impose restrictions on the purchase or sale of securities for their own accounts and the accounts of certain affiliated persons. Additionally: • All Trinity Neches and employee trades will be reviewed by the Chief Compliance Officer, and • Principals and employees will not receive a more favorable execution price on a particular day than those received by our investment advisory clients. Notwithstanding the above, Trinity Neches, and/or its officers, directors or employees may purchase for themselves similar or different securities as purchased or recommended for investment advisory clients of Trinity Neches, and different securities or transactions may be recommended for different investment advisory clients of Trinity Neches. Trinity Neches will also maintain quarterly reports on all personal securities transactions, except transactions in investment company securities and/or other exempt transactions. You may request a complete copy of our Code of Ethics by contacting us at the address, telephone, or email on the cover page of this Part 2. Prohibition on Use of Insider Information We have adopted policies and procedures to prevent the misuse of “insider” information (material, non-public information). A copy of such policies and procedures is available to any person upon request. Item 12 - Brokerage Practices Allocation of Investment Opportunities and Orders We have adopted the following policies and procedures related to the fair allocation of investment opportunities. These policies are designed to help ensure that each client receives fair and equitable treatment in the investment process: • Transactions in the same security on behalf of more than one client are aggregated to facilitate best execution and to reduce brokerage commissions and/or other costs. • Aggregated executions to participating accounts are allocated in a fair, equitable and objective manner and permissible reasons are delineated for deviating from the standard methodology and the related approval requirements. 8  • Accounts in which our employees have a beneficial interest, or in which Trinity Neches has a conflict of interest, do not receive preferential treatment. Our allocation procedures differ for each of our equity strategies. When orders are generated, the decision on which accounts should participate, and in what amount, is based on the type of security or other asset, the present or desired structure of the various portfolios and the nature of the account’s goals. Other factors include risk tolerance, tax status, permitted investment techniques and, for fixed-income accounts, the size of the account and settlement and other practical considerations. How we select Brokers and Custodians We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • capability to execute, clear and settle trades (buy and sell securities for your account) • capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • the breadth of investment products made available (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • availability of investment research and tools that assist us in making investment decisions • quality of services • competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them • reputation, financial strength, and stability of the provider • their prior service to us and our other clients • availability of other products and services that benefit us, as discussed below The determining factor is not always the lowest commission cost, but whether the transaction represents the best execution for the account. Principal vs. Agency Transactions We do not participate in principal or agency transactions. Research Services/Soft Dollars We recommend that our clients use Charles Schwab & Co., Inc. (Schwab) or Ascensus Trust Company (Ascensus Trust) to custody client assets. Please refer to the section below “The Custodian and Brokers We Use” for more detail. Trading Aggregation Practices We might aggregate trades if it is beneficial to our clients, and we have established trade allocation policies to ensure all of our clients are treated fairly. A trade aggregation and allocation policy would include: 9  • Determining how a particular security is to be allocated before placing the trade with the broker. • Bunching single orders into blocks when possible, to obtain the best execution at the best security price available. • We attempt to provide the same investment opportunities to all of our clients, but when investment opportunities have a limited allocation, we consider the following in making the allocation decision: • Your goals and objectives. • Your risk tolerance. • Your financial situation, including your asset base, liquidity, and the character of your non- investable assets. • Any restrictions or limitations you have placed on your portfolio. We make every attempt to consistently apply a trade aggregation and allocation policy; however, in cases where use of this policy results in unfair or inequitable treatment to some or all of our clients, we may deviate from this policy. Directed Brokerage We do not accept client-directed brokerage arrangements. The Custodian and Brokers We Use We do not maintain custody of your assets that we manage (although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15 Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. and Ascensus Trust Company (”Custodian”) as the custodian. We are independently owned and operated and not affiliated with the custodian. The Custodian will hold your assets in a brokerage account and buy and sell securities when we/you instruct them to. While we recommend that you use Schwab Ascensus Trust as custodian/broker, you will decide whether to do so and open your account by entering into an agreement directly with them. Even though your account is maintained at the Custodian, we can still use other brokers to execute trades for your account. Other Fees in Connection with Trading In our efforts to achieve best execution of portfolio transactions, we may trade securities for client accounts by utilizing electronic marketplaces or trading platforms. Some of these electronic systems may impose additional service fees or commissions. We may pay these fees directly to the provider of the service or these fees may be included in the execution price of a security. Our intention is that we will only use such systems and incur such fees if we believe that doing so helps us to achieve the best execution of the applicable transaction, taking into account all relevant factors under the circumstances. For example, we will consider the speed of the transaction, the price of the security, our ability to block the transaction and other factors discussed in this Brokerage Practices section in connection with trading of stocks and bonds. The Custodian generally does not charge you separately for custody services but are compensated by charging you commissions or other fees on trades. In addition to commissions, the Custodian charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have the Custodian execute most trades for your account. Accounts with Different Investment Objectives 10  It is possible that we may manage accounts of clients whose investment objectives are substantially different from one another. As a result, it is possible that it would be appropriate for us to sell a security “short” from one account while holding it “long” in another account. This may occur if we manage an account that involves significant short- term trading or pursues unique options strategies. In general, however, our positions with regard to any security will be net long. We seek to avoid a conflict of interest by attempting to limit such situations to, for example, an instance in which there is a readily available supply of the securities being purchased or sold and the transactions in a security do not affect its market price. Item 13 - Review of Accounts We use a software tool to monitor client accounts. The software provides notices of client contributions, withdrawals, or significant changes in asset allocation. The notices trigger a full review of the portfolio. Software notices are generated on a daily basis. Additional reviews are prompted by volatile market conditions, changes in your goals and objectives, or changes in our model portfolios. Portfolios are managed based on risk tolerance, tax status, asset location, portfolio size and other factors. Potential trades are usually generated by our software, reviewed by an advisor representative, and submitted to custodians electronically for trading. The decision to trade is based on several factors, including deviations from target weighting, tax consequences, holding period, manager changes and the size of the trade. We believe that frequent contact is critical to ensure financial plans and investment portfolios continue to meet client needs. Consequently, we make every effort to discuss your portfolio with you through phone conversations and meetings. We also ask you to contact us if your financial circumstances change. We do not have a limitation on the number of client accounts assigned to any particular advisor representative, nor is there a precise sequence or review schedule. Accounts are reviewed by Milton “Chip” Thiel, Jr., Managing Member. The clients will generally receive monthly reports from the custodian detailing assets and all activity in the account. Some less active accounts may only receive quarterly reports from the custodian. Other custodians, such as 401(k) custodians, provide at least quarterly reports, with some providing monthly reports. Schwab and Ascensus Trust provide access to client portfolios through their websites. We can provide updated (through the end of the previous trading day) consolidated performance and holding summaries upon request. We provide detailed quarterly reports to all Private Wealth Management clients. Quarterly reports include information on asset allocation, current performance, and historical performance for all managed portfolios. We strongly suggest you compare your Trinity Neches quarterly statement to your custodian statements. Monthly reports summarizing asset allocation, performance and unrealized gains also are available by request. Item 14 - Client Referrals and Other Compensation Client referrals On occasion we pay a finder's fee to an unrelated third party for client referrals. Such fees will only be paid to whom we have entered into a formal referral (solicitor) agreement. Such arrangements will comply with the requirements set forth pursuant to the Investment Advisers Act of 1940, and/or applicable state statutes, to the extent they apply. 11  Other compensation We may receive support services and products from Schwab or Ascensus Trust for free or at a discounted price, in order to better service client accounts. Support services include: Investment-related research. • • Pricing information and market data. • Software and other technology to provide access to client account data. • Compliance and practice management-related publications, seminars, or consulting services. • Discounted or free attendance at conferences, meetings, and other events. • Marketing support. • Computer hardware, software, or other products. Clients do not pay more for these services as a result of this arrangement. Trinity Neches has negotiated fixed transaction fees for the benefit of all our clients. Also, a portion of our trading involves buying and selling no transaction fee funds. Trinity Neches has made no commitment to any institution to invest a specific amount or percentage of client assets in any specific funds, securities, or other investment products as a result of the above arrangement. Item 15 - Custody We do not have custody of client assets. Therefore, each client must select a custodian and may be required to pay custodian fees. Also, clients will incur brokerage and other transaction costs in the course of our management of their accounts. (See the section in this brochure entitled, “Brokerage Practices” for a discussion of how we make brokerage decisions that affect client accounts.) Clients will receive an account statement from one or more qualified custodians covering the funds and securities in their account(s). Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. We urge you to carefully review such statements. Item 16 - Investment Discretion Discretionary authority for trading Trinity Neches requires full discretion to manage Private Wealth accounts, which is given upon signing our advisory agreement. This grants us authorization to invest and reinvest the assets in your portfolio, make investment changes and other decisions without your prior consultation or approval. Common client restrictions include: Individual stocks you would prefer are held in your accounts for tax purposes or other reasons. • • Managers or asset classes you cannot hold in your accounts. We do not accept non-discretionary management accounts as it is difficult for us to effectively manage portfolios without full discretion, due to time lags, documentation, and regulatory requirements. Limited power of attorney 12  Clients are required to provide limited power of attorney for each of your accounts. This document gives Trinity Neches the authority to direct and or effect investments, for the direct payment of fees, custodial fees and or other charges incurred by the managed account. Wrap Account Management We do not participate in the management of wrap account programs. Item 17 - Voting Client Securities Trinity Neches does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive their proxies or other solicitations directly from their custodian. Item 18 - Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about Trinity Neches’ financial condition. We do not have any financial commitment(s) that impairs our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding. We do not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance, therefore have no material additional financial disclosures to make. Business Continuity Plan We have a Business Continuity Plan that addresses how the Firm will respond to events that may disrupt its business. If the main telephone line is inactive, please email chip@TrinityNeches.com or contact your custodian. We will resume operations as quickly as possible (preferably within twenty-four hours) depending on the severity of the business disruption. Our Business Continuity Plan covers data backup and recovery, mission critical systems financial and operational assessments, alternative communications, alternate business locations, regulatory reporting, and the assurance of prompt access to funds and securities for our customers. Trinity Neches has an obligation to act in the best interests of the firm’s clients. Trinity Neches believes this obligation extends beyond the life and capacity of its Managing Member, Milton “Chip” Thiel, Jr. As part of this obligation, the firm implemented a formal succession plan with Kings Path Partners, LLC and its founder, Mike Mulcahy, in October of 2018. This was done to ensure the firm’s clients have, at most, a minimal disruption of service in the event of death or incapacitation of Milton “Chip” Thiel, Jr. Additional details regarding the firm’s Business Continuity Plan are available upon request. Privacy Notice To Customers We do not disclose nonpublic personal information about our individual clients or former clients except as permitted by law. We restrict access to nonpublic personal information about you (that we may obtain from your account and your transactions) to those employees who need to know that information to provide products or services to you or to alert you to new, enhanced, or improved products or services we provide. We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information. 13